Troy Corporation (“Troy,” “we” or “us”) operates the website at http://www.troycorp.com (the “Site”), which is hosted in the United States. Together with our Terms of Use (available on the Site), the privacy statement set forth below (the “Privacy Statement”) identifies what information the Site may collect, and for what purposes it may be used. Please read the following carefully to understand the type of information that we collect and how we use such information. If you do not agree to how your information may be processed by us in the ways described in this Privacy Statement, please do not use this Site or any of the services that we provide. Please contact us (as set forth below) if you have any questions or concerns about this Privacy Statement or the use of your information.

Our products, services and our Sites are not intended for individuals for their personal use.

We reserve the right to modify this Privacy Statement at any time. We will notify you by posting an amendment to the privacy policy on the Site, the homepage and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this policy, we will notify you here, by email or by means of a notice on our home page. We encourage you to frequently review the Privacy Statement for any modifications. If you do not wish for your Personally Identifiable Information to be processed in the way described under this Privacy Statement (as may be updated), please do not continue to use the Site or any services we offer.

The following definitions apply throughout this Privacy Statement:

“Anonymous Information”: This is information that does not personally identify users, by itself or in combination with other information. We may gather this information to improve the performance of the Site. The Anonymous Information we may collect can include information such as the type of browser you are using, IP address, the pages you view and the length of your visit to the Site.

“Personally Identifiable Information”: This is information that may include your name, address, telephone number, fax number, company name, e-mail address and relevant details about the product or service that interests you. This information may be gathered when you send us an e-mail, when you complete the specific web page request form or complete the web page user registration form. In all such cases you choose whether to provide us with the Personally Identifiable Information, although certain portions of the Site may not be available to you or we may not be able to respond to your inquiry effectively if you do not provide such information.

“Sensitive Personal Information”: This is Personally Identifiable Information that reveals genetic data or biometric data, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the health or sex life of the individual.

This Privacy Statement applies only to activities we engage in on the Site and does not apply to activities that are “offline” or unrelated to the Site.

In general, you can visit the Site without telling us who you are. However, we do collect Personally Identifiable Information in the following ways:

Personally Identifiable Information you give to us: This is Personally Identifiable Information that you give to us through your interaction with the Site, by applying for a job, by filling in the “Contact Us” form on the Site, by registering through the “User Registration Form” on the Site, by filling out the “Order Request Form” on the Site or by corresponding with us by phone, email or otherwise. Such information may include your name, email address, telephone number, postal address, employer, job title and other data that will allow us to facilitate your request and answer your questions. Job applicants may also be asked to provide information including confirmation that the applicant is over the age of 18. While applicants can provide their gender, this is a voluntary disclosure and not required in the application process.

For business transactions for your company, please only provide to us business contact information (your business email address, your business phone number and your office address). If you do set up an account with us, and enter a password, please do not use the same password for multiple accounts, and in no event should you use a password for our Site that you also use for personal accounts.

Personally Identifiable Information we collect about you: With respect to each of your visits to the Site, we may automatically collect the following information that may be Personally Identifiable Information as it may (when combined) enable you to be identified:

	Technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
	Information about your visit to the Site, including the dates and times you use the Site, length of visits to particular pages, page interaction data (such as scrolling, clicks and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on the Site.

Information we receive from other sources: This is information we receive about you from any third party source or from “off-line” activities. We may combine this information with other information that we may have collected about you via the Site. Your employer may provide to us information about you as the point of contact for your employer’s account with us. We also receive information about you if you apply for a job with us from the third party provider that we use for background checks (where allowed by applicable law). We also may receive your information from a trade show that you and we attend.

We do not collect any Sensitive Personal Information about you without your express consent, and in any event we only collect Sensitive Personal Information regarding employees and applicants for employment as necessary for background checks (where allowed by applicable law), onboarding and employment related matters (including but not limited to payroll, benefits and related matters).

We do not disclose Personally Identifiable information to third parties for their marketing purposes without your prior consent, but we do use third party software and services to assist us with collecting and analyzing information regarding use of the Site. We may also disclose your information to enforce and/or to fulfill our agreements, if required by law, and in relation to your employment (for example to our third party benefits provider and payroll company).

The Site does not currently employ technologies, such as cookies and web beacons (also known as clear GIFs), to automatically receive and store certain information about your use of the Site. However, utilizing custom HTTP modules, we do track and collect information about your web browsing activities on the Site. Such information may be used to provide you with customer service, and to better understand how the Site is used, among other things.

Uses by Troy. Troy uses the Personally Identifiable Information you provide through the Site in a manner that is consistent with this Privacy Statement and in accordance with law. If you provide Personally Identifiable Information for a particular purpose, we may use it in connection with that purpose. For instance, if you ask us a question via email, we may use the email address or other point of contact you provide to answer your question or resolve your problem. We use the information collected through the Site for statistical purposes and for improving the Site, as well as for our marketing purposes and we may also send to you commercial emails regarding our products and services. We also collect information as to who has viewed the videos and product information available on our site and this information may be shared with our sales force to follow up with you regarding the video and product information content. Where you have requested a sample, we will use your information to respond to your request. We often use a third party’s software to effect this collection and analysis. As a practical matter, we must release your mailing address to a postal or courier service to deliver information you requested.

WE DO NOT SELL YOUR PERSONALLY IDENTIFIABLE INFORMATION TO THIRD PARTIES. We do share your personal information with our Affiliates. We may, however, transfer your Personally Identifiable Information in connection with a corporate restructure, sale or merger (see Onward Transfers below.) Most commonly, we will use your Personally Identifiable Information in the following circumstances:

	Where we need to perform the contract we are about to enter into or have entered into with you, including the Terms of Use; or
	Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
	Where we need to comply with a legal or regulatory obligation.

Specifically, we use Personally Identifiable Information in the following ways:

Personally Identifiable Information that you give to us. We will use this information:

	To set up a customer or vendor account with us;
	To post employee testimonials where we have first received consent from the employee to share the employee’s name, likeness and/or testimonial.
	To respond to your inquiries;
	To send service-related announcements where we deem necessary, such as a temporary suspension of the Site or specific functions referenced on the Site for maintenance;
	We may send to you marketing materials regarding our products and services. If you no longer wish to receive marketing emails, please follow the “unsubscribe” instructions included in those communications. Personally Identifiable Information will not be rented, sold or traded with or to third parties for marketing purposes; we may, however share your information with our Affiliates.

We may also disclose Personally Identifiable Information in order to respond to a subpoena, court order or other such request. We may also provide such Personally Identifiable Information in response to a law enforcement agency’s request or as otherwise required by law.

It is important that the Personally Identifiable Information we hold about you is accurate and current. Please keep us informed if such information changes during your relationship with us.

Information that we collect about you. We will use this information, which may contain Personally Identifiable Information:

	To deliver the Site effectively and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
	To improve the Site to ensure that content is presented in the most effective manner for you and for your computer or other device; and
	As part of our efforts to keep the Site safe and secure.

Personally Identifiable Information we receive from other sources.

We may combine Personally Identifiable Information you give us and/or that we collect or receive about you. We will use the combined Personally Identifiable Information for the purposes set forth above (depending on the types of Personal Information we receive).

You agree that we have the right to share your Personally Identifiable Information with:

We are ISO certified, and in connection with our recertification annually, we conduct customer surveys and then disclose the survey responses on an anonymous basis as required to third parties involved in the review and recertification process. In our User Registration Form, we will first you whether you would like to be on our E-Mailing List, and your agreement to do so would include your consent to include you in our annual ISO customer survey. We also conduct, for our internal purposes, an annual customer survey. We share this information with our Affiliates and so inform you when you chose to respond to our surveys. Data protection laws in some of these locations may not have the same level of protection for your Personally Identifiable Information as those of your home country. However, where we share your Personally Identifiable Information with our Troy group companies located outside the European Economic Area (“EEA”), we only do so with your informed consent where required. We may also provide your information to our Affiliates where the product or service regarding which you have presented an inquiry the Affiliate(s) are best equipped to respond to your inquiry or concern. We maintain reasonable measures intended to protect your information, but remind you to only provide to us business points of contact (your work number, work email and related points of contact).

Third party service providers that may collect Personally Identifiable Information for a particular contracted purpose (e.g., a job search company to post jobs and collect resumes, and third party vendors that undertake background checks on employee candidates. When signing up for these services, we only share Personally Identifiable Information as necessary for the third party service provider to provide the requested service. These companies are not authorized to keep or use your Personally Identifiable Information for any other purpose. If Troy has knowledge that a third party is using or disclosing Personally Identifiable Information in a manner contrary to this Privacy Statement and/or our contract with that third party, we will take reasonable steps to prevent or stop the use or disclosure.

We will disclose your Personally Identifiable Information to third parties:

	ONWARD TRANSFERS: If we sell or buy any business or assets, in which case we will disclose your Personally Identifiable Information to the seller or buyer of such business or assets; or
	If we are under a duty to disclose or share your Personally Identifiable Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of us, our users, or others. (See Legal Disclaimer, below.)

Troy maintains industry accepted safeguards and precautions intended to protect Personally Identifiable Information in our possession from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We follow generally accepted industry standards to protect the Personally Identifiable Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect the Personally Identifiable Information that we receive, we cannot guarantee its absolute security. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the internet and wireless networks.

Where required by applicable privacy laws, rules and/or regulations, and otherwise where reasonably practical, upon request, Troy will grant individuals reasonable access to the Personally Identifiable Information that we hold about them. Further, where required by applicable privacy laws, rules and/or regulations, and otherwise where reasonably practical, upon request, we will erase your information from our systems. Subject to the foregoing, Troy takes reasonable steps to permit individuals to correct, amend, or delete Personally Identifiable Information that is demonstrated to be inaccurate or incomplete. We will not proceed with these requests unless and until we verify your right to make the request and to access the information sought, as provided below. Further, even where you ask us to delete your information or to change your information, we may need to keep your information as it relates to our business transactions or issues with you and/or your employer. Moreover, if it is your employer who has provided to us certain information about you, you may need to contact your employer first.

If you are based in the EEA, you have a number of rights in relation to how we process your Personally Identifiable Information. These include:

	The right to access the Personally Identifiable Information that we may hold about you;
	The right to rectify any inaccurate Personally Identifiable Information that we may hold about you;
	The right to have your Personally Identifiable Information erased in certain circumstances, for example, where it is no longer necessary for us to process your Personally Identifiable Information to fulfil our processing purposes, or where you have successfully exercised your right to object to the processing;
	The right to object to the processing of your Personally Identifiable Information which may be exercised in certain circumstances, for example, where your own legitimate interests outweigh ours; and
	The right to have your data ported to a new service provider if you no longer wish to use the services. Note, however, that this is a B2B Website and we have your information only in relation to you pursuant to your business. Where we receive any such request, we may require you and your employer to confirm such a request.

You can exercise any of these rights at any time by contacting us at:

Troy – EU HR Department
Freundallee 9 a. D-30173 Hannover, Germany
Email: DataPrivacyEU@troycorp.com
Telephone: +49 (0) 511 8998 8312

No fee is charges where prohibited by law; and generally, we will not otherwise charge a fee unless requests are excessive.

You will not have to pay a fee to access your Personally Identifiable Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those situations.

Verification: What we may need from you.

We may need to request specific information from you to help us confirm your identify and ensure your right to access your Personally Identifiable Information (or to exercise any of your other rights). This is a security measure to ensure that Personally Identifiable Information is not disclose to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond.

We try to respond to all legitimated requests within one month. Occasionally, it may take us longer than one month if your request is particularly complex or you have may a number of requests. In such case, we will notify you and keep you informed of our efforts.

The Personally Identifiable Information that we collect from you through the Site will be transferred to, and stored within, the United States. We will take all steps reasonably necessary to ensure that your data is protected in accordance with this Privacy Statement. All Personally Identifiable Information you provide to us is stored on our servers. We back up the data on our servers through a third party cloud provider. We require this provider not to use or access our data other than to fulfill its contract with us.

We reserve the right to disclose Personally Identifiable Information as required by law and when that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our website, or when otherwise requested by law enforcement.

Any questions or concerns regarding the use or disclosure of Personally Identifiable Information should be directed to Troy at the address given below. Troy will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personally Identifiable Information in accordance with the principles contained in this Privacy Statement.

EEA Users only: Should you have cause to complain about how we handle your Personally Identifiable Information, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the national supervisory authority within your jurisdiction.

Adherence by Troy to these data privacy principles may be limited (a) to the extent required to respond to a legal obligation, and (b) to the extent expressly permitted by an applicable law, rule or regulation.

Questions or comments regarding this Privacy Statement should be submitted to Troy by email to DataPrivacy@troycorp.com.

For the Troy companies, a data protection officer has been appointed. The responsibility of the Data Protection Officer is to monitor compliance with data protection at all times. If individuals should have any questions or suggestions with respect to data protection law, they may contact our Date Protection Officer at any time at the following:

If you are located in the EEA:
Data Protection Officer
Troy – EU HR Department
Freundallee 9 a. D-30173 Hannover, Germany
Email: DataPrivacyEU@troycorp.com
Telephone: +49 (0) 511 8998 8312

If you are located outside the EEA:
Data Protection Officer
Troy Corporation – Law Department
8 Vreeland Rd.
Florham Park, NJ 07932
Email: DataPrivacy@troycorp.com

This notice supplements the information provided above and applies solely to consumers who reside in the State of California (“consumers’ or “you”). We adopt this policy to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Our products, services and our Sites are not intended for individuals and/or households for their personal use.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal information”). Personal information does not include information that is publicly available from government records or de-identified or aggregated consumer information. As described below, in the past 12 months, we have not disclosed or sold California consumers’ personal information to third parties for business or commercial purposes.

We obtain the personal information listed above from the forms you complete or products or services you purchase, and by observing your actions on our Site.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

	To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request product information or to apply for employment, we will used that personal information to respond to your inquiry.
	To provide, support, personalize and develop our Site, products and services.
	To create, maintain, customize and secure your account with us.
	To process your requests, purchases, transactions and payments and prevent transactional fraud.
	To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
	To personalize your Site experience and deliver content and product and service offerings relevant to your interests.
	To help maintain the safety, integrity and security of the Site, products and services, databases and other technology assets, and business.
	For testing, research, analytics and product development, including to develop and improve our Site, products and services.
	To respond to law enforcement requests, and as required by applicable law, court order or governmental regulations.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice.

Your Rights Regarding Personal Information

The CCPA provides consumers (California residents) with specific rights regarding their personal information:

	For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties; however, we do not sell your information to any third party except in the case of an Onward Transfer (pursuant to a corporate restructure, merger or sale);
	The right to know the categories and specific items of personal information we collect, use and disclose about you, the categories of sources from which we collected your personal information, our purposes for collecting your personal information, the categories of your personal information that we have disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
	The right to request that we delete the personal information that we have collected from you or maintain about you. You will be asked to clearly submit your request to delete and to separately confirm your choice; and
	The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

As stated above in this Privacy Statement, we use third parties to help us manage this Site and to send to you information and offers regarding our products. These service providers are contractually restricted from using the information we provide to them for any other purpose.

To exercise any of the above rights, please contact us at:

Data Protection Officer
Troy Corporation – Law Department
8 Vreeland Rd.
Florham Park, NJ 07932
Email: DataPrivacy@troycorp.com

Verifying Your Request

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Verifiable consumer requests must:

	Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or you are an authorized representative
	Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We will attempt to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reasons and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive or manifestly unfounded. It we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.