By using this Website, and/or requesting further information or a quote on this Website or through other means, or checking the terms and conditions box, you agree to the WBCA and HB Terms and Conditions set forth below, including, without limitation, the Privacy Policy

Wire Belt Company of America, Inc. (WBCA), has adopted this Privacy Shield Policy (Policy) to establish and maintain an adequate level of Personal Data privacy protection.

Wire Belt Company of America, Inc. (WBCA) complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Individual Customers in the European Union member countries and Switzerland.  WBCA certify that they adhere to the Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Privacy Principles, the Privacy Shield Privacy Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov.

Scope:
This Privacy Shield Privacy Policy (the “Policy”) sets forth the privacy principles that WBCA follows when processing Personal Data received from customers or prospective customers located in the European Economic Area (“EEA”) and Switzerland, while providing services. This Policy also does not apply to Personal Data collected through WBCA’s recruiting process.  For purposes of this Policy, Personal Data means information about an identified or identifiable individual that is received by WBCA in the U.S. from the EEA or Switzerland and recorded in any form.
The Wire Belt Company GDPR Team is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Wire Belt Company GDPR Team using the details set out below.

Our contact details are:    

Full name of legal entity:Wire Belt Company of America, Inc.
Email address for Privacy Shield Policy questions:gdprteam@wirebelt.com
Address:Wire Belt Company of America
154 Harvey Rd
Londonderry, NH  03053
Telephone Number:1 (603) 644-2500
  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

What we don’t do:
We will never sell your personal information.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
What we may collect:  We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status and title.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username or similar identifier, your interests, preferences, and feedback.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

To find out more about the types of lawful basis that we will rely on to process your personal data.  Please see the glossary for further information.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at gdprteam@wirebelt.com
2 a.  Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at gdprteam@wirebelt.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To register you as a new customer(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our
products/services)
To enable you to partake in a prize draw, competition or complete a survey(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them
and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services,
 network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them,
to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep
our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

  1. Disclosures of your personal data to Third Parties:

We may have to share your personal data with the parties set out below for the purposes set out in the table above. : WBCA complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • We may appoint third party service providers (known as processors) who will handle information on our behalf, for example to provide data storage or other technology services.  We only let that happen if we are satisfied with their levels of security.  Keep in mind that when you give us personal information it could be being transferred, stored or processed in a location anywhere in the world (due to cloud technology).
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • Opt Out:  Should you desire to opt out and not want us to share your personal information with third parties as set out above or from using your personal data beyond what we have disclosed, please contact gdprteam@wirebelt.com

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Wire Belt group of companies for marketing purposes.

Third-party links:  Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Third Party Websites and Applications
WBCA has a presence on several social media/Web 2.0 platforms (Facebook, YouTube, Twitter, LinkedIn, and other third-party services)) and clearly contain the WBCA’s official logo. Each of these web sites provides WBCA unique ways of sharing information. It also allows visitors with a way to communicate with the agency. Some may allow visitors to log in, create profiles and save information in those profiles. We do not collect any personally identifiable information about you through your use of these social media/Web 2.0 platforms. Further, WBCA has no control over the third-party’s use of this information and is not liable regarding the third-party’s safeguarding your information. These web sites (any website you visit not managed by WBCA) have their own privacy, security and accessibility policies and are out of our control.

  1. Recourse, Enforcement & Liability: 

In compliance with the Privacy Shield Principles, WBCA commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact WBCA at: gdprteam@wirebelt.com or by calling 603/644-2500 
WBCA has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
WBCA has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles to an independent recourse mechanism and have adopted the EU DPA (Data Protection Authorities) scheme, operated by the USCIB (United States Council for International Business). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by WBCA, please visit  https://www.privacyshield.uscib.org for more information and to file a complaint at no cost to you. 
In addition to the above dispute resolution mechanisms, you may invoke binding arbitration if their complaint is not resolved by the USCIB or by the Department of Commerce after referral from the relevant data protection authority in the EEA or Switzerland. For more information about binding arbitration, visit https://www.privacyshield.gov
The Federal Trade Commission (FTC) has jurisdiction over the Company’s compliance with the Privacy Shield.
All WBCA employees who handle Personal Data from Europe and Switzerland are required to comply with the Principles stated in this Policy.

  1. Your rights:  Access and control of your information:

You have the right to all of the following:  Please contact gdprteam@wirebelt.com to make your request.

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information and that we may not be able to comply with your wishes.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

In all instances, please email gdprteam@wirebelt.com or call 001 (603)644-2500 to request assistance.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at gdprteam@wirebelt.com

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties

Other companies in Wire Belt Company of America’s Group.

External Third Parties

  • Service providers acting as processors based outside of the US or European Economic Area (EEA) who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services and our email marketing services.
  • The IRS, Customs, regulators and other Public authorities acting as processors or joint controllers based in the United States who require reporting of processing activities in certain circumstances, Including National Security or Law Enforcement requirements.

Cookies
To better serve our visitors, we use technology to track new and returning visitors actions while on the website. These small files are commonly referred to as “cookies.” Our cookies do not contain any personally-identifiable information. Our web measurement applications compare the behavior of new and returning visitors in the aggregate to help us identify work flows and trends and also resolve common problems on our site.
Cookies are small files that Web servers place on a user’s hard drive. They can serve several functions:

  • they allow the Web site to identify you as a previous visitor each time you access a site;
  • they track what information you view at a site (important to WBCA to ensure visitors find what they are looking for);
  • in the more advanced cases they track your movements through many Web sites but not the whole Web;
  • businesses use them for customer convenience to allow them to produce a list of items to buy and pay for them all at one time and to garner information about what individuals are buying at their sites;
  • advertisers use them to determine the effectiveness of their marketing and offer insights into consumer preferences and tastes by collecting data from many Web sites; and
  • they can be used to help a Web site tailor screens for each customer’s preference.

We will retain data the technology makes available only as long as required by law or other approved records schedule as applicable.
If you are concerned about the potential use of the information gathered from your computer by cookies, you can set your browser to prompt you before it accepts a cookie. You can remove or block the use of web measurement and customization technologies by changing the setting of your browser to block cookies as described at USA.Gov.