About Us Products Capabilities Corporate/Social Responsibility Employment Contact Privacy Policy Home Privacy Policy Privacy Policy Last Updated: April 15, 2020 HDT Automotive Solutions, LLC (“HDT Automotive”) is committed to protecting your privacy. This privacy policy applies to all users of the HDT Automotive website, available at https://hdt-auto.com (the “Website”), and explains how we collect and use the personal data we collect when you visit the Website. Our processing of your personal data is subject to this privacy policy and any subsequent updates. General HDT Automotive is the controller of personal data collected through the Website. “Personal data” is defined as information that identifies, or can be used to identify, an individual. We collect personal data both directly and indirectly when you visit the Website. We will only process your personal data when we have a legal basis to do so, which include your consent, fulfilment of a contractual obligation, and where we have a legitimate interest to process your personal data, provided that our interests do not outweigh your individual rights and freedoms. Our legitimate interests include: Investigating, preventing, and protecting against fraud, security risks, threats to you and others, and violations of this policy; Protecting and defending our rights and properties, including intellectual property; Complying with laws and regulations that apply to us, as well as responding to requests from law enforcement or government authorities or as otherwise required by law; Improving your experiences with our products and services; Understanding and improving the Website, user experience, and customer relationships; and Enabling our business operations. Where we rely on your permission to process your personal data, you have the right to change, withdraw, or withhold your consent. Personal Data Collection We collect personal data that you choose to share with us, as well as information provided directly by your browser or device when you visit the Website. The information we collect will depend on how you interact with the Website. Personal Data Collected from You Submit a Contact Request When you contact us via our “Contact” form, we will ask you for your first and last name, email address, and telephone number. We will also collect the content of your message, which will contain any additional personal data you choose to include. We collect this information for the purpose of responding to your contact request(s). Subscribe to Newsletter and Communications If you elect to receive our newsletter or other email communications, including marketing content, we will collect your first and last name, email address, address/location, and telephone number. We collect this information for the purpose of providing you with your requested content, including providing you with marketing and promotional materials. Apply for a Job When you apply for a job with us, we collect your first and last name, email address, address/location, and telephone number. We also collect your resume, which includes any additional personal information you wish to share. We collect this information for the purpose of evaluating your candidacy and communicating with you regarding current and future employment opportunities with HDT Automotive. Personal Data Collected via Web-Based Technologies Browser or Device Information We automatically receive and record information on our server logs from your browser, including cookie information and the page(s) you request. We collect this data for the following general purposes: Optimizing your user experience Fulfilling your requests for products and services Promoting and improving services We also engage a third party to analyze Website trends, administer the site, and track user movement for aggregate usage analysis, which recognizes you by your IP address(es). We do not directly collect or receive your IP address(es) and will only review anonymous, aggregate analytics information. This Website usage information enables us to provide our users with an ever-improving site, service, and general offering. Cookies and Web Beacons We set and access cookies on your computer or browser. “Cookies” are small files placed on your computer by your browser and are often used to make websites work, as well as provide information to the website operator. We collect this information for the purpose of Website usage and analytic reports as described in the Google Analytics section and to remember language preferences. When you first visit the Website, you will be asked to accept our use of cookies. If you decline to accept our use of cookies, you will not be able to access the Website. Communications you receive from us, as well as pages of the Website, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that enable us to track the success of a campaign by reporting back when the user completes an action on the website after arriving through an advertisement.. The web beacons only collect aggregate, anonymous data and cannot be traced back to you individually. Third-Party Cookies and Web Beacons Some content or applications on the Website are served by third parties, including content providers and application providers. Our third-party partners may use cookies alone or in conjunction with web beacons or other tracking technologies already in your browser to collect information about you when you visit the Website. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites and other online services. Third-party cookies and web technologies are controlled by our third-party partners and are not subject to this privacy policy. If you have any questions about the practices of such third party, you should contact the responsible third-party directly. Google Analytics We use Google Analytics to provide us Website usage and analytic reports. To provide us with such information, Google recognizes your IP address(es); however, Google only provides us with anonymous, aggregate usage data that cannot be used by us to individually identify you. You may choose not to share your data with Google by installing the Google Analytics opt-out browser add-on, which instructs your browser not to provide the Website usage data to Google Analytics. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout to install the browser add-on. Please note that installing the Google Analytics opt-out browser add-on will only disable the use of Google Analytics and will not prevent data from being sent to the Website itself or to other web analytics services. Personal Data Use How we use your personal data will depend on how you interact with the Website and the personal data you have shared with us. Respond to Your Requests We use your personal data to respond to your requests, including your communications and job applications. Enhance Website and User Experience We use the information regarding the use of the Website to analyze and administer the site and track user movement for web analytics purposes. This Website usage information enables us to provide you with an ever-improving site, service, and general offering. Except where you have provided consent for us to use your identifiable personal data, for our analytics research, we only use anonymous, aggregate data that cannot be used to identify you individually. Conduct Marketing and Advertising When you opt to receive our newsletter and/or marketing communications, we will use your personal data to provide you with updates and communications about our products. You may opt-out of such communications by clicking the “Unsubscribe” link at the bottom of any marketing electronic communication received from us. You may also contact us at marketing@hdt-auto.com to request that we remove you from our marketing communications. Meet Legal and Regulatory Obligations In certain circumstances, we may be required to disclose your personal data as part of court or other legal proceedings or to regulators or as otherwise required by law. We will only share the information we are required to disclose by law and only when we are required to do so. Security and Fraud Prevention When necessary, we will use your personal data to preserve the security of the Website, systems, and personal data in our control. If necessary, we will also use your personal data to investigate possible fraud, violations of this privacy policy and to prevent any attempted harm to our users. Personal Data Sharing and Disclosure We share your personal data when you have granted us permission to do so, when it is necessary to fulfill our obligations to you, or when it is in the legitimate interest of our business to do so, provided that our interests do not outweigh your individual rights and freedoms. Support Vendors When necessary, we share your data with third-party vendors working on our behalf to provide specific business support services, website analytics, mailing and communications, website hosting and management, and marketing programs. Website Analytics Companies We share anonymous, aggregate information regarding visitors to the Website with third-party website analytics companies (see also the information on Google Analytics, above). These companies use this data to provide us with insight regarding our web usage patterns. As we only share anonymous, aggregate data, this information cannot be traced back to you individually by us. Legal Requirements As required by law, regulation, or legal process, we will share your personal data with government authorities, enforcement officials, or third parties as necessary to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. Security and Fraud Prevention Efforts When necessary, we will share your personal data to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or suspected violations of this privacy policy, our agreements or arrangements with you or other policies in effect from time to time to which you are subject, or as otherwise required by law. Sale of Business We reserve the right to transfer your personal data in the event we sell or transfer all or a portion of our business or its assets. In such event, your personal data will continue to be governed by this privacy policy. Your Choices and Rights EU Data Subject Rights If you are an EU data subject, we provide you with choices about the collection, use, and disclosure of your personal data. You may exercise these rights by contacting us at the information provided at the end of this privacy policy under the heading “Contact Information.” Unless explicitly stated otherwise, we will respond to your request as soon as possible, but at the latest within one month. Your rights include: Accessing your personal data to know what information we have collected about you and how it has been shared; Requesting the deletion of all or some of your personal data; Changing or correcting inaccurate or outdated information; Objecting to, limiting, or restricting use of all or some of your personal data; and Requesting a copy of your personal data, including in a portable format. You also have the right to lodge a complaint with your supervisory authority if you believe we have violated your privacy rights or applicable laws and regulations. California Consumer Privacy Rights We provide our California consumers with specific rights regarding their personal data. The section describes the rights that you have under the California Consumer Privacy Act (“CCPA”) and explains how to exercise those rights. In the past 12 months, we have collected the following categories of personal data under CCPA: Category Examples Identifiers Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers Personal Information Under California Customer Records Statute Name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number Internet or Network Activity Browsing history, search history, and information regarding a Consumer’s interaction with an Internet Web site, application, or advertisement Geolocation Data Physical location only to the extent your IP address may indicate your general physical location * Some personal data included in this category may overlap with other categories. We have disclosed the above information for business purposes to our affiliates, service providers, customers, and other users as described in this policy. Sale of Personal Data In the preceding 12 months, we have not sold (as defined by CCPA) personal data from all of the categories of personal data listed above. We have not and will not sell the personal data of minors under 16 years of age to non-affiliated third parties without affirmative authorization. Right to Know About Personal Data Collected, Used, or Disclosed You have the right to request that we disclose certain information to you about our collection, use and disclosure of your personal data over the past 12 months. Once we receive your request and verify your identity, we will disclose to you: (1) the categories of personal data we collected about you; (2) the categories of sources for the personal data; (3) our business or commercial purpose for collecting or disclosing that personal data; (4) the categories of third parties with whom we shared that personal data; and (5) the specific pieces of personal data we collected about you in the preceding 12 months. Right to Delete Personal Data Collected or Maintained You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request and verify your identity, we will permanently delete (and direct our service providers to delete) your personal data from our records, unless a legal exception to deletion applies. In our response to your request to delete, we will specify the manner in which we have deleted your personal data or, if we must deny your deletion request, the basis for this refusal. Right to Non-Discrimination for Exercise of Privacy Rights We will not discriminate against you for exercising any of your rights by: (1) denying you goods or services; (2) charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (3) providing you a different level or quality of goods or services; or (4) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. Exercising Your Rights To exercise the rights described above, please submit a verifiable consumer request to us by either: Calling us at 313 329-0787 Email security@hdt-auto.com Authorizing an Agent You may designate an authorized agent to submit your consumer request on your behalf, so long the authorized agent has your written permission to do so and you have taken steps to verify your identity directly with us. Verifying Your Request We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal data provided in a verifiable consumer request to verify your identity or authority to make the request. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. To verify your identity, we ask that you to provide us with the following information when you submit your request: (1) first name, (2) last name, and (3) phone number or email. We will use the above information to verify your identity. Depending on your type of request or the information requested by you, we may require additional information to verify your identity and fulfill your request. Cookie Disclaimer The user must agree to the HDT cookie disclaimer upon entering the website. If the user is on the website, they have agreed to the terms of the disclaimer. Other Important Information Cross-Border Data Transfers We process data both inside and outside the United States. It is important to know that data protection laws in the United States may not be as strong as those in your country. Where we transfer your personal data from the European Economic Area (“EEA”) to a location outside the EEA, we will only transfer your data if an appropriate level of protection for your personal data is guaranteed, such as where we have contractual obligations to protect or transfer data with certain safeguards in place. To ensure the continued protection of your personal data while in our care, we take appropriate organizational and technical measures. In addition, we may transfer your personal data if one of the legal exceptions for such transfer can be invoked, such as with your consent or in execution of an agreement you have with us. Third-Party Websites This website may contain links to websites owned or operated by third parties. This privacy notice applies only to the Websites and not to any third-party websites. Security We have implemented organizational and technical safeguards for protecting the personal data you share with us. These measures include SSL technology to secure the Website. Data Retention Information will be securely transmitted over email following the submission of your form; data will be retained until deletion. Children Under the Age of 16 We do not knowingly collect personal data from individuals under the age of 16, unless the personal data is submitted by a provider for use of our services and with parental consent. The Website is not intended for anyone under the age of 16, and no one under the age of 16 may provide information on this Website. Privacy Policy Changes We may update or revise this policy at any time, at our sole discretion. Any changes to our privacy policy will apply to your personal data from the “Last Updated” date at the top of the privacy policy. You can find the most current version of our privacy policy at any time by clicking on the “Privacy Policy” link at the bottom of the Website. If we make material changes to our privacy policy, we will notify you of those changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on the Website. Contact Information For questions, concerns, or to exercise your privacy rights, please contact us at: HDT Automotive Solutions, LLC c/o Privacy Officer 38701 Seven Mile Road, Suite 265 Livonia, Michigan, USA 48152 Security@hdt-auto.com 313 329-0787 PRIVACY This communication is intended to inform all relevant parties about the fact that the Data Protection Officer, designated for all European plants and pursuant to art. 37 of the 2016/679 EU Regulation (“GDPR”) is Mr. Bottacin Fabrizio. Pursuant to art. 38 paragraph 4 of the GDPR, interested parties can contact the Data Protection Officer without any formalities for all matters concerning the processing of their personal data and the exercise of their rights. Dott. Ing. Bottacin can be contacted at: Mob: +39-339-6054422 email: fabrizio.bottacin@ingpec.eu Privacy Policy | Contact Us Huron Inc — Phone: (810) 359-5344 Fax: (810) 359-4018