Effective Date: January 1, 2023
Last Updated Date: January 1, 2023
Table of Contents
- Purpose of This Policy
- Personal Information We Collect
- How Personal Information Is Collected
- Use of Personal Information
- Disclosing Personal Information
- Personal Information of Children
- Notice to Investors
- Third Party Websites
- How We Protect Your Personal Information
- How Long We Store Your Personal Information
- Access and Choice
- Contact Information
Purpose of This Policy
We have separate privacy policies and notices that apply to our employees and personnel as well as former employees and personnel.
Personal Information We Collect
We collect personal information about individuals we interact with in our business, such as individuals at our customers, suppliers and service providers as well as job applicants and independent contractors. We collect personal information so that we can operate our business and supply our products and services. The following provides examples of the types of personal information that we collect, or have collected in the preceding 12 months, from you for our purposes and how we use that information.
|Category||Examples and Explanation|
Personal information subject to the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
|We collect identifiers of the individuals we interact with in our business, such as a name, alias, address, phone number, Internet Protocol address, and email address. We may also collect other identifiers, including Social Security number, driver’s license number, passport number, financial account information, or other similar identifiers where necessary to administer our relationship with individuals, such as making payments for services rendered, allowing us to receive goods or services, and identifying individuals that visit our facilities. We may also collect information about an individual, such as title, education and employment information. |
We also collect this information from job applicants as necessary to process job applications, conduct employment screenings or checks, or for government-required screenings.
|Protected classifications under California, federal, or other laws||Examples of these protected classifications that we may collect include age, race, citizenship, marital status, sex, and gender. |
With respect to our customers, suppliers, contractors and other similar individuals that we interact with in our business context, we may collect information contained in government identifications to verify identity and citizenship status if necessary to comply with the legal or contractual requirements and to secure our facilities.
With respect to job applicants, we collect this category of information to the extent included on applications and resumes, and to process job applications, conduct employment screenings, tests or checks, or for government-required screenings.
|Commercial information||We do not collect information about products or services purchased by individuals for their personal or household purposes. We do keep records of products or services purchased by our customers in the business-to-business context. We collect information about interests or affiliations, preferences for marketing communications, products and services, and feedback about our business.|
|Geolocation information||We collect information about physical location, such as identifying when individuals are physically present at our facilities, or if an individual manually provides location information or enables a mobile device to send us precise location information.|
|Sensory information||We collect audio, electronic, or visual information, such as voice messages and video surveillance for security purposes at our facilities in the ordinary course of business.|
|Professional or employment-related information||We collect professional or employment-related information of individuals that we interact with in a business-to-business context, including contacts at our customers, suppliers and contractors. We also collect this information with respect to job applicants, such as job history, to the extent required to process job applications conduct employment screenings, tests or checks, or for government-required screenings.|
|Non-public education information.||We collect non-public education records, such as grades and transcripts, per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)), with respect to job applicants where necessary to process applications and to conduct interviews.|
Some of the categories above are considered “sensitive personal information” under the applicable privacy laws (e.g., California):
- government identifier, including social security, driver’s license, state identification card, or passport number as described above;
- financial accounts numbers as necessary to pay for services rendered by suppliers and contractors as described above;
- precise geolocation as described above;
- race or ethnic origin, as described above.
We only collect this information where permitted and in accordance with applicable law, and in certain instances only where you voluntarily provide such information.
We collect health information about individuals that visit our facilities or attend functions we host as necessary to safely operate those facilities and functions. We may ask visitors to our facilities to supply identification, which may include personal information such as government identification number. Visitors may be recorded on our electronic security systems.
Where required by law or to satisfy the requirements of governmental entities with which we transact business, we may require persons that transact business with us or that visit our facilities to provide name, address, U.S. citizenship status, country of origin or nationality, or other personal information to allow us to perform required screenings.
Additional information about the personal information that we collect is described in the Privacy Notice for California Consumers – California Privacy Rights.
How Personal Information Is Collected
We receive personal information from the following sources:
- directly from you, such as when you complete forms, contact us, or visit our facilities;
- from your devices, such as when you visit this Site;
- affiliates and subsidiaries;
- other sources, such as customers and prime contractors; internet websites; social media and similar digital sources; governmental entities and regulatory authorities; and service providers, suppliers, distributors and sales representatives that provide goods and services. With respect to job applicants, service providers include companies that perform background checks and credit checks or that administer assessments.
We may also receive your personal information from third parties in connection with a business transition such as a merger, reorganization, acquisition, or purchase of all or a portion of business assets. In such transactions, personal information is generally one of the transferred business assets and we may receive your personal information as an asset in any such transaction.
If you are a job applicant and you provide us with any personal information about other individuals, such as your reference(s), it is your responsibility to make sure you have their permission to share this information with us.
Our Site uses information gathering technologies, such as cookies and similar technologies, to collect information as you navigate the Site.
Types of Cookies. Cookies may be session cookies, which are temporary cookies that expire or are erased when you close your browser. Cookies may also be persistent cookies that have an expiration date and therefore stay in your browser until they expire or you delete them.
We may use first party cookies on our Site, which are cookies placed by us to collect information about you or to personalize your experience on the Site.
We differentiate between cookies that are essential for the technical features of the Site and optional analytics and advertising cookies.
|Essential Cookies||These are cookies that the Site needs in order to function, and that enable you to move around and use the Site and features. Without these essential cookies, the Site will not perform as smoothly for you as we would like it to and we may not be able to provide certain services or features you request. Examples of where these cookies are used include: to determine when you are signed in; to determine when your account has been inactive; and for other troubleshooting and security purposes.|
|Functional Cookies||Functional cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.|
|Analytics Cookies||Analytics cookies allow us to understand more about how many visitors we have to our Site, how many times they visit us and how many times a user viewed specific pages within our Site. Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our Site multiple times, we cannot use them to find out details such as your name or address. We use Google Analytics. For more information about Google Analytics, please refer to “How Google Uses Information From Sites or Apps that Use Our Services”, which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. If you would like to disable Google Analytics on your browser, you can visit https://tools.google.com/dlpage/gaoptout.|
Cookies Used on this Site. The following describes the specific cookies we may use on our Site and the purpose for which they are used.
|s_cc||This cookie, which is on the Investor page of our Site, is provided by Adobe and tests whether or not the visitor accepts cookies.||Analytics|
|s_vi||This cookie, which is on the Investor page of our Site, is provided by Adobe and tracks user movement anonymously throughout the Site as part of the analytics suite.||Analytics|
|DrupalVisitorMobile||This cookie, which is on the Investor page of our Site, determines whether the Site visitor is originating from a mobile device and routes the user to a mobile-version if applicable.||Essential|
|GZIP XXXX%5Fo||These cookies, which are on the Investor page of our Site, are provided by HIS Markit and are used to allow visitors to view the stock chart.||Functional|
|cookieconsent_status||This cookie allows us to know whether or not a visitor has clicked on the Site’s cookie notification banner so that visitors that have clicked on the banner do not see it in subsequent visits.||Functional|
|JSESSIONID||The JSESSIONID cookie is used by New Relic to store a session identifier so that New Relic can monitor session counts for an application.||Essential|
|_ga||The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.||Analytics|
|_gid||Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website’s performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.||Analytics|
|_gat||Google Analytics sets this cookie to throttle request rate.||Analytics|
Cookie Settings. Our Site sets cookies by default. But you can configure your browser settings to limit or exclude the use of these and other cookies, or to delete these and other cookies that have already been placed on your computer.
However if you disable or delete certain cookies in your browser settings, you might not be able to access or use important functions or features of this Site. Cookie settings vary from one browser to another, so you may need to consult instructions for the particular third party provider of your browser for instructions. The links below provide you with information on how to manage and disable cookies on popular browsers:
Cookies in Emails. We may place cookies or similar technologies in emails that we send to you to assist us in determining if an email recipient has opened an email or to understand how a recipient has interacted with the email, such as clicking on a link. If you do not want to accept cookies in emails, you can close the email before downloading any images or clicking on any links. You can also set your browser to restrict cookies or to reject them. In some cases, depending on your email or browser cookie settings, cookies in emails may be automatically accepted. Please refer to your browser settings for more information.
Use of Personal Information
We use personal information we collect for our business or commercial purposes, which include one or more of the following:
- Providing our products and services to customers, including maintaining or servicing accounts; providing customer service; processing or fulfilling orders and transactions; verifying customer information; processing payments; advertising or marketing our products and services to customers; hosting or attending industry events and tradeshows;
- Human resources and recruitment, to manage all aspects of our relationships with job applicants and independent contractors, including paying for services, fees and expenses; performing screenings, checks and verifications, to the extent permitted by applicable law; providing access to facilities; and where appropriate for job applicants, for recruiting, evaluating applications, and checking references;
- Legal compliance and protection, including investigating and responding to claims against us; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; responding to legal process; protecting against malicious, deceptive, fraudulent, or illegal activity and prosecution of those responsible; complying with internal policies and procedures; complying with applicable laws and regulatory requirements (e.g., tax, health and safety); monitoring and ensuring compliance with applicable policies and procedures;
- Information technology and security, including detecting security incidents; debugging to identify and repair errors that impair existing intended functionality; monitoring the use of IT resources; performing data analytics; securing our facilities;
- Auditing including auditing compliance and financial auditing;
- Business administration, including engaging in strategic planning and project management; maintaining records related to business activities, budgeting and financial management; undertaking internal research for technology development and demonstration, including without limitation to developing and improving our products, services and our websites; undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade or enhance the service or device; protecting the rights, safety, and property of the Company, our employees, and/or others;
- Acquisition and business transactions including evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; other business reorganizations; and
- Other purposes as described to you when collecting your personal information.
Disclosing Personal Information
We may provide your personal information to the following third parties:
- affiliates and subsidiaries;
- customers and third party business partners, as necessary in connection with business operations;
- service providers and suppliers (for example IT companies and others who we engage to provide us services or to whom we outsource work to);
- distributors and sales representatives;
- professional advisors (such as our accountants or legal counsel);
- government entities and regulatory authorities; and
- other disclosures with your consent.
We have centralized certain aspects of our data processing and administration in accordance with applicable laws in order to allow us to better manage our business. That centralization may result in our providing your personal information to our affiliates. For example, your personal information may be provided to managers or staff of our affiliates in other locations to enable those affiliates to provide us with support services.
As we continue to develop our business, we may buy or sell businesses in transactions such as mergers, reorganizations, acquisitions, or the purchase of all or a portion of business assets. We or our assets may also be purchased in these types of transactions. Personal information is often transferred as part of these transactions.
We may be required to disclose personal information if we are compelled to do so by a court of law or requested to do so by a governmental entity, regulatory authority or stock exchange, or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws.
Please note that the types of third parties to whom we provide your personal information as set out above is non-exhaustive and there may be circumstances where we need to provide your personal information to other third parties in order to operate this Site and our business. Where required by applicable law, we will notify you of any other circumstances where we would share your information on a case-by-case basis.
Personal Information of Children
This Site is not intended for or directed to children under 16 years of age. We do not knowingly collect personal information from children under 16 without parental consent. If we become aware that a child under the age of 16 has provided us with personal information, we will delete the information from our records.
Notice to Investors
Certain pages of this Site allow investors in ESCO Technologies Inc. to obtain publicly available information about ESCO Technologies Inc. and its subsidiaries. Investors may view and/or request information through this Site on our Investor Center here. An investor may choose to request information from us or sign up to receive email alerts from us. As part of that process, the investor may choose to provide the investor’s name, title, company, investor type, country, address and other comments. We will use this information to verify an investor’s identity and to process any requests for information.
Third Party Websites
How We Protect Your Personal Information
We maintain appropriate technical and organizational measures to protect your personal information from accidental loss and from unauthorized access, use, interference, destruction, alteration, and disclosure. For example, we have implemented data protections policies, information about you is stored on secured information systems, and physical access to our information systems is limited to authorized individuals.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
How Long We Store Your Personal Information
Access and Choice
Where required by law, we provide you with access to the personal information maintained about you and a reasonable opportunity to correct, amend or delete the information where it is inaccurate or has been processed erroneously, as appropriate. We may limit or deny access to personal information where the burden or expense of providing access would be disproportionate to the risks to your privacy or where the rights of third parties would be violated.
Effective Date: January 1, 2023
Last Updated Date: January 1, 2023
PRIVACY NOTICE FOR CALIFORNIA CONSUMERS – CALIFORNIA PRIVACY RIGHTS
Last Updated: January 1, 2023
This section called Privacy Notice for California Consumers – California Privacy Rights:
- is intended to meet the requirements of the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020, and applicable regulations (“California Privacy Laws”);
- applies solely to those individuals who reside in the State of California and whose personal information (as defined below) is collected by us, who are referred to in this Notice as “consumers” or “you“.
This Privacy Notice for California Consumers applies to ESCO Technologies Inc., which is referred to in this Privacy Notice for California Consumers as the “Company”, “we”, “us”.
We have a separate Privacy Notice applicable to our employees and personnel as well as former employees and personnel. Current and former employees and personnel who would like a copy of this separate Privacy Notice can contact us in the manner described in Privacy Notice for California Consumers – Contact Information below.
This section describes our current practices as well as our practices for the 12-month period prior to the date of this Privacy Notice for California Consumers.
Personal Information We Collect About California Consumers
When we talk about personal information in this Privacy Notice for California Consumers, we mean 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 does not include information that has been excluded from the scope of the California Privacy Laws, such as publicly available information from government records; information you make available to the public generally; information from widely distributed media; de-identified or aggregated information; and certain categories of information governed by other sector-specific privacy laws.
How We Collect Your Personal Information
How We Use Your Personal Information
Disclosing Personal Information
Sale of Personal Information and Sharing for Advertising Purposes
We do not sell your personal information. We also do not share your personal information with third parties for cross-context behavioral advertising.
How Long We Keep Personal Information
How We Protect Your Personal Information
California Consumer Privacy Rights
The California Privacy Laws provide consumers with rights regarding their personal information. This section describes your California Privacy Laws rights and explains how to exercise those rights. We will comply with your requests to exercise your rights, unless an exception under the California Privacy Laws applies. Please note that the Company may require the use of your personal information to administer your job applicant relationship with us. Therefore, in some instances, we may not be able to process your request.
Your Right to Know and Data Portability
You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. You generally have the right to receive this personal information in a structured, commonly used, and machine-readable format so you can transmit this personal information to another entity.
Your Right to Deletion
You have the right to request that we delete any of your personal information that we collect from you and retain.
Your Right to Correct
You have the right to request that we correct inaccurate personal information that we maintain about you.
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights provided by the California Privacy Laws. This includes the right not to be retaliated against for the exercise of your rights.
How to Submit a Request
To exercise the rights described above, please submit a verifiable consumer request to us by either:
- Emailing us at [email protected].
- Completing the webform available by clicking here
- Calling this toll-free number: 833-601-0844
In submitting a request to exercise your rights, please provide us with the State in which you reside, your name, a return email or phone number where we can contact you, or indicate we can reply to the email you send to us. Please also identify which privacy rights you would like to exercise with sufficient detail that allows us to properly understand, evaluate, and respond to your request.
In responding to you, we will take steps to verify your identity before granting you access to your personal information or comply with your request as described in Verifying Requests below.
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.
Although we have a separate Privacy Notice applicable to our employees and personnel as well as former employees and personnel, those persons can use the instructions in this section to submit their requests.
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 that the personal information relates to you.
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide us with information about you to verify your identity. If we cannot verify your identity, we may decline your request as permitted by the California Privacy Laws.
The type of information that we ask for varies depending on the type and sensitivity of the personal information that is the subject of the request and other factors required by the California Privacy Laws. If additional information is required to verify your request, we may contact you to provide us with that information before responding to your request for access or deletion. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You can designate an authorized agent to make a request to know, delete or correct your personal information on your behalf. These requests should be sent to us in the same manner you would submit a request described above. That authorized agent must provide us with a copy of the signed written permission from you. We can deny a request from an authorized agent that does not submit proof that the agent is authorized by you to act on your behalf. We may also require you to verify your own identity directly with us (as described above) and confirm with us that you provided that permission.
To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Privacy Notice for California Consumers is available in alternative formats upon request. Please contact us as described in the section called California Privacy Laws Notice Contact Information to request this Privacy Notice in an alternative format. We will respond to your request within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request.
Privacy Notice for California Consumers – Contact Information
If you have any questions or comments about this Notice, or questions or concerns about our privacy policies and practices, please contact us at:
Email: [email protected]
ESCO Technologies Inc.
9900A Clayton Road
St. Louis, Missouri 63124
Attn: Data Privacy, General Counsel