November 1, 2018

This Privacy Policy explains the practices of Mitutoyo America Corporation regarding personal information collected from you or about you on our online sites, offline by means of written or verbal communications with us, mobile applications, social networking presence, customer relationship management system, enterprise resource planning system, email system, quotation system, or from other sources.

COLLECTION AND USE OF PERSONAL INFORMATION

Personal information may be collected from individuals through our websites or by other means (such as email, fax, mail, phone, mobile applications, third-party applications, business partners, and other third-parties such as commercial data vendors and public databases). This Privacy Policy details the principal avenues you may provide personal information and the types of personal information you may submit, as well as the manner in which we may use your personal information.

Business Alerts, Newsletters and Other Communications
– You may provide personal information such as your name and contact details to receive business alerts, newsletters and other communications (including emails). Sending communications and information you have requested, and communicating with you about our products and services are legitimate business interests. If you no longer wish to receive such business alerts, newsletters or other communications from us, you may unsubscribe at any time by contacting us via the contact information provided in the “Contact Us” section of this Privacy Policy.

Business Relationship
– Access to information related to our business relationship or Mitutoyo America Corporation products on our websites and mobile applications may use your personal information. This personal information may facilitate your use of the websites or mobile applications. You may also choose to provide, or we may obtain, your personal information at trade shows or from our distributors. Managing our business relationship and executing marketing and sales activities are a legitimate business interests.

You may also choose to connect to us by means of social networking services (e.g., Facebook, YouTube or Twitter). When you connect to us in this manner we may collect personal information that you have provided to that service in accordance with the service’s applicable Terms of Use and your privacy settings within that social networking service. We may also decide to supplement information you have provided to us by obtaining additional demographic information about you from third-party sources. Improving our communications with you, gaining better insight into your needs, and improving our business, where permitted under local law, are legitimate business interests.

Careers
– Individuals apply for jobs with Mitutoyo America Corporation through the Mitutoyo America website, third-party job posting sites, job fairs, or directly to the business locations. Often, third-party service providers maintain the information job seekers provide through this process. The information submitted by job seekers, such as name, contact details and any other information relevant to the application is used to evaluate their qualifications for employment and to contact them regarding possible employment opportunities. It is in our legitimate business interest to use this information in the selection process and to communicate with you, and it will be necessary to provide us with this information so that we can assess your application.

Job seekers may also choose to provide sensitive personal information such as gender or ethnic background. Providing this data is optional and not required to apply for a job with Mitutoyo America Corporation. Mitutoyo America Corporation does not consider this information in evaluating candidates’ qualifications for employment.

Contact
– You may contact us with questions, requests or comments through the “Contact” link on our website, or by means of the contact information provided in the “Contact Us” section of this Privacy Policy. When you do so, we may ask for your personal information to verify your identity or to track the inquiry internally to ensure we respond to your questions, requests or comments.

Contests, Sweepstakes, Promotions and E-Commerce
– If you wish to participate in contests, sweepstakes, promotions or e-commerce activities related to Mitutoyo America Corporation, your name, contact details and payment details may be collected. If you provide another person’s information to us, you must first obtain appropriate consent from that individual prior to providing this information to us and in order for us to use this information in the manner indicated. Using your personal information to communicate with you and to process your requests and purchases is a legitimate business interest. When we process personal information to meet our legitimate business interests, we put in place robust safeguards to ensure that your privacy is protected. Mitutoyo America Corporation also ensures that its legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Contractual Obligations
– If you are a vendor or a contractor, we may ask you to provide personal information such as your name, photo, contact details or business and financial details to establish and administer your account, process payments, and for compliance with internal and legal requirements. We use your information for this purpose so that we can comply with our contractual obligations to you.

Feedback
– Submitting feedback on our websites is an option. If you choose to give us your feedback, we may ask for your personal information. We may also ask about your experience using our websites. Enhancing our website, evaluating the quality of our products or communicating with you about our products and services is a legitimate business interest.

Incidents and Allegations – When you provide information about an incident or allegation, detailed personal information including your name, contact details and any relevant information about the incident or allegation may be collected. We use these details to investigate and comply with any applicable company or legal requirement. We may transfer and disclose your information to third-parties as required in the course of the investigation or to comply with any legal obligation related to the information you provide.

Information Technology Security
– We may collect personal information when detecting and defending against security threats in accordance with our legitimate business interests and our legal obligations. We use various IT tools to detect and defend against online security threats (e.g., attacks, viruses, malware, spam, phishing, malicious web content), to promote business continuity of our information systems and assets, and to maintain optimal performance of our IT systems. To ensure physical security of our facilities we may, where permitted under local law, utilize surveillance systems and/or location tracking while you are on Company property.

Other Uses of Information
– We may use your personal information collected for internal general business purposes in accordance with our legitimate business interests. These purposes include, for example administration of our websites, data analytics, fraud prevention and compliance with our legal obligations, standards, policies and procedures (i.e., due diligence checks and sanction screening where applicable).

We may obtain your explicit consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to our direct marketing activities, or when we process sensitive personal information). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy policy.

INFORMATION COLLECTED BY AUTOMATED MEANS

When you visit and interact with our websites and applications, we may collect “Other Information” that does not inherently reveal your specific identity, in order to learn how to best tailor our websites for our visitors. Examples of what Other Information we may collect and how we and third-party service providers may collect this information include:

Aggregation Information
– Aggregated user information does not personally identify you or any other user (for example, we may aggregate user information to calculate the percentage of our users who have a particular telephone area code). Aggregated data is treated in accordance with this Privacy Policy.

Application Usage Data
– When you download and use an application, we and our service providers may track and collect application usage data, such as the date and time the application on your device accesses our servers and what information and files have been downloaded to the application based on your device number.

Browser and Device Information
– Certain information is collected by most browsers or automatically through your device, such as your computer type, operating system name and version, device manufacturer and model, Internet browser type and version and the name and version of the online services (such as the applications) you are using. We use this information to ensure that the online services function properly.

Cookies
– Cookies are pieces of information stored directly on the computer or mobile device that you are using. Cookies allow us to collect information such as browser type, time spent on the online services, pages visited, referring URL, and other aggregated website traffic data. We and our service providers use this information for security purposes, to facilitate navigation, to display information more effectively, to collect statistical information, and to personalize your experience while online.

Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the online services or to send you advertisements and marketing emails. We may also use cookies or other technologies to track responses to our online advertisements and marketing emails. You can opt out of such interest-based advertising. Opting out of interest-based advertising does not mean you will no longer see advertising online. It does mean that the company or companies from which you opt out will no longer show ads that have been tailored to your interests.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You can choose whether to accept cookies by changing the settings on your browser or, depending on your jurisdiction, by managing your tracking preferences as noted in a separately posted cookie statement or via a posted cookie manager. If, however, you do not accept cookies, you may experience some inconvenience in your use of the online services. For example, we may not be able to recognize your computer, and you may need to log in every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs. At this time, we do not respond to browser “Do-Not-Track” signals except in jurisdictions where we are required to do so by law.

IP Address
– Your Internet Service Provider (ISP) automatically assigns the computer that you are using an IP address. Whenever a user accesses the online services, an IP address may be identified and logged automatically in our server log files, along with the time of the visit and the page(s) that you visited. Collecting IP addresses is standard practice. Collection is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering our online services. We may also derive your approximate location from your IP address to understand from what regions of the world our website visitors come.

Physical Location and Mobile Location-Based Services
– We may collect the physical location of your device if you have consented to us doing so, by, for example, using satellite, cell phone tower, Wi-Fi signals, or other technologies. We may use your device’s physical location to provide you with personalized location-based services and content.

If you have downloaded one of our applications, you may enroll to receive offers by agreeing to the use of technologies that enable us to collect information about your location through your mobile device’s Bluetooth or similar capabilities. We will collect this information if you opt-in through the application (either during your initial login or later) to receive the offers and by enabling these capabilities on your mobile device.

Pixel Tags or Similar Technologies
– Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some online services to, among other things, track the actions of users of the online services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the online services and response rates. We also use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of our services and report on activities and trends. These services may collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ ,and opt-out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

SHARING YOUR INFORMATION

We do not sell or otherwise disclose your personal information except as described in this Privacy Policy. We may also share your information as disclosed at the time you provide it and in the following circumstances:

Business Transfers
– We may disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Policy. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

Law Enforcement Agencies, Courts, Regulators, Government Authorities or other Third Parties
– We may transfer and disclose your information to third parties (i) to comply with a legal obligation, (ii) when we believe in good faith that the law requires it, (iii) at the request of governmental authorities conducting an investigation, (iv) to verify or enforce our policies, Terms of Use and other agreements or to protect the rights, property, or safety of Mitutoyo America Corporation, our customers, or others (v) to respond to an emergency, (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity or (vii) otherwise to protect the rights, property, safety, or security of third parties, users of our services or the public.

Marketing Partners
– In some cases, we may permit certain network advertising companies and publishers to collect personal information on our sites. In addition, our business partners may access personal information about you that we have combined with such business partners’ data. We may collaborate with our business partners to jointly send tailored promotional communications to you using the combined set of information. If you prefer not to receive these jointly sent communications, you can opt out by following the instructions included in any such communication.

Non-Personal Information
– We may share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties.

Sharing With Your Consent
– Our services may present you with the opportunity to opt in to receive information or marketing offers from third parties or to otherwise consent to the sharing of your information with third parties. If you agree to have your personal information shared, your personal information will be disclosed to the third-party subject to the privacy notice and business practices of that third party.

Third-Party Service Providers
– In order to carry out your requests; make various features, services and materials available to you through the services; respond to your inquiries; and for other purposes described in the “Collection and Use of Personal Information” section of this Privacy Policy, we may share your personal information or usage information with third parties. These third parties perform functions on our behalf (or on behalf of our partners). These functions may include: hosting or operating our sites; analyzing data; providing customer service; mailing product samples; managing payments; providing marketing or promotional assistance (such as in connection with winner selection, prize fulfillment and as required by law); or assist with risk management, compliance, legal and audit functions. These third parties may include: advertisers; sponsors or other third parties. We have not authorized these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

AUTOMATED DECISIONS ABOUT YOU

We may make automated decisions about you using your personal information in the following circumstances:

Mitutoyo America Corporation may use automated processing when evaluating large numbers of applicants for job vacancies. For these purposes, we request that you create a profile and answer some job-related questions to evaluate your skills as compared to the published job requirements. An algorithm may then be used to determine which candidates will be allowed to proceed to the next step within the selection process. We consider this data and process to be relevant because it will assist us to select the applicant most suitable for our vacancies. The outcome of the evaluation may have an impact on whether you are offered a role for the vacancy to which you have applied.

You can contact us by means of the contact information provided in the “Contact Us” section of this Privacy Policy to request further information about automated decision-making, object to our use of automated decision-making, or request an automated decision to be reviewed by us if required by local law.

USER-GENERATED CONTENT

Some of our services and social networking features may enable you to submit your own content for public posting. Information you post in this fashion becomes public information and is not subject to this Privacy Policy. Certain areas of our websites and our social media pages may enable users to submit personal information to Mitutoyo America Corporation. Mitutoyo America Corporation will use such information in accordance with the website’s Privacy Policy. Postings, letters, and other submissions become the property of Mitutoyo America Corporation and may be reproduced in whole or in part, including your name, for any purpose and in any manner.

LINKS TO OTHER SITES

Our websites and communications may provide links to other websites, including to social networks or partners that may use our logo(s) as part of a co-branding agreement. To the extent that any linked services are not provided by Mitutoyo America Corporation, we are not responsible for the services, or any of the content found on these websites. If you provide information on and use third-party services or websites, the privacy policy and terms of service on those sites are applicable. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

PROTECTING PERSONAL INFORMATION

In proportion to the sensitivity of the information, we maintain reasonable administrative, technical and/or physical safeguards and appropriate security measures to protect personal information from loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide. However, we cannot guarantee the security of your personal information, as no electronic data transmission or storage of information is completely secure. If an incident is reported affecting your information, we will investigate and comply with all required reporting obligations.

RETAINING PERSONAL INFORMATION

Mitutoyo America Corporation will keep your personal information for as long as we have a business relationship. Once our relationship has concluded, we will retain your personal information for a period of time that enables us to:

  • Maintain business records for analysis and/or audit purposes
  • Comply with record retention requirements under the law
  • Defend or bring any existing or potential legal claims
  • Address any complaints regarding the services

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

CHANGING AND ACCESSING YOUR PERSONAL INFORMATION

You may have certain rights regarding your personal information, subject to local law. These include the following rights to:

  • access your personal information;
  • correct the information we hold about you;
  • erase your personal information;
  • restrict our use of your personal information;
  • object to our use of your personal information;
  • withdraw your consent for us to use your personal information, if applicable;
  • receive your personal information in a usable electronic format and transmit it to a third party (right to data portability); and
  • lodge a complaint with your local data protection authority (if applicable).

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. Please note that we will likely require additional information from you in order to verify your identity and respond to your requests. If you would like to discuss or exercise your applicable rights, subject to limitations established under local law, please contact us via the contact information provided in the “How to Contact Us” section of this Privacy Policy. We will respond to you within a reasonable time and within the time limits established by applicable law.

CHILDREN

Our services are generally not directed to children under 16. We do not knowingly collect personal information from anyone under 16 without parental consent. If you become aware that we have collected personal information from a child under the age of 16 without parental consent, please let us know so we can take appropriate action.

CALIFORNIA RESIDENTS

If you are a California resident and have provided us with your personal information, you may ask us to refrain from sharing your personal information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes. Please tell us your preference by contacting us via the contact information in the “How to Contact Us” section of this Privacy Policy.

UPDATES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time. We will always indicate at the top of the Policy when it was most recently updated. If we substantially change this Privacy Policy, we will notify you of the changes. Any changes will be effective immediately upon the posting unless otherwise indicated. Where changes to this Privacy Policy will have a fundamental impact on the nature of processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights.

CONTACT US

If you have any questions or comments about this Privacy Policy or if you would like us to remove or update information we have about you or your preferences, please email us or write to the following applicable contact at Mitutoyo America Corporation:

Mitutoyo America Corporation
965 Corporate Blvd
Aurora, IL 60502

Email: Privacy.Policy@mitutoyo.com