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Privacy Policy

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Last Updated: 08-Oct-2024

This Privacy Notice describes how Hultec TopCo, LP and its affiliates and subsidiaries (“Hultec,” “us,” “our,” or “we”) collects, uses, discloses, and otherwise processes Personal Data about our business contacts, customers, job applicants, and visitors to hultec.com (our “Site”).

“Personal Data” means any information relating directly or indirectly to an identified or identifiable person and includes other similarly defined terms, such as “personal information,” as used in applicable privacy and data protection laws.

Personal Data Collection

We obtain the following categories of Personal Data from various sources, including directly from you, such as when you enter your Personal Data into our online forms; automatically when you use our Site; from the organization you represent; from public sources; and from our vendors, business partners, and other third parties. The Personal Data we obtain about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

  • Contact Information and Other Identifiers, including name, contact details, unique personal identifier, online identifier, and IP address.
  • Professional and Employment-Related Information, including job title; affiliated company name and location; job responsibilities; and recruitment information, such as work experience, professional references, education history, professional training and certifications, and other information submitted in connection with a job application or inquiry or included in a resume/curriculum vitae.
  • Demographic information, including nationality, citizenship, and country of residence.
  • Communications Content, including inquiries about and orders for our products and services; recommendations or other feedback regarding our Site, products, and services; and information about your preferences.
  • Audio, Electronic, Visual, or Similar Information, including audio recordings of customer service calls.
  • Internet or Other Electronic Network Activity Information, including internet or other similar activity, browsing history, search history, device data, and information about your Site interactions and engagement with our social media accounts.

If you do not provide certain types of Personal Data, we may be unable to provide our products or services.

We may combine your Personal Data with other data we obtain from our Site, our services, and other parties. Your Personal Data may be converted into deidentified, anonymized, or aggregated data, such that it is no longer reasonably associated with you, not considered Personal Data under applicable law, and not subject to this Privacy Notice.

Personal Data Use

We and our vendors may use or otherwise process the Personal Data described above for the following purposes.

  • Services and Transactions, including providing information about our products and services; processing transactions; managing customer service requests; responding to your inquiries; managing accounts; and contacting you regarding products, services, billing, and transactions.
  • Site Operations, including maintaining, operating, optimizing, and providing access to our Site; identifying Site visitors; monitoring and analyzing Site usage and trends; evaluating how our Site performs; ensuring our Site operates effectively; repairing or improving the quality of the Site; and tracking and responding to quality and security issues.
  • Business Operations, including performing system administration and technology management; carrying out internal administration, such as recordkeeping and auditing; identifying prospective customers, partners, and vendors; managing our relationships with our customers, partners, and vendors; improving our Site, business, products, and services; and otherwise operating our business.
  • Recruitment, including opening and maintaining job application records, assessing employment eligibility, facilitating recruitment and hiring processes, and performing reference and background checks.
  • Security and Integrity, including protecting the security and effective functioning of our Site and information technology systems; authenticating users; enforcing our policies and terms; and generally safeguarding our Site.
  • Advertising and Marketing, including sending marketing and promotional materials relating to our products, services, and promotions; measuring the use of our services and effectiveness of our advertising and marketing; understanding how you interact with our advertising and marketing, including our emails to you; and developing insights to improve our Site and provide our users with enhanced features and functionalities.
  • Legal and Compliance, including managing risks, investigations, reporting, and other compliance activities; preventing, identifying, investigating, and responding to fraud, illegal or malicious activities, and other activity that violates or may violate applicable laws, regulations, legal processes, or our policies; responding to court orders or other government and law enforcement mandates or requests; identifying or managing legal actions related to our or others’ rights or property; supporting actual or threatened claims, defenses, or declarations in a case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel; fulfilling our legal obligations; and enforcing compliance with applicable laws, regulations, or legal processes as well as industry standards and our company policies, including export control requirements.

We process Personal Data pursuant to the following legal bases, as permitted by applicable law, including:

  • Performance of a Contract or Steps to Enter into a Contract, including when carrying out transactions and responding to requests related to our products and services.
  • Compliance with a Legal Obligation, including using Personal Data for recordkeeping to substantiate tax liability, complying with export requirements, responding to regulatory inquiries, and participating in judicial or administrative proceedings.
  • With your Consent, including providing direct marketing or targeted advertising when consent is required by applicable law.
  • As Necessary for Legitimate Interests, including carrying out business operations, supporting our commercial interests, operating our Site, maintaining security and integrity, preventing fraud, and complying with our contractual obligations.

Personal Data Disclosure

We may disclose the Personal Data described above to the following categories of recipients.

  • Hultec Affiliates, Subsidiaries, and Business Partners to carry out our business operations, as described in this Privacy Notice.
  • Service Providers, Suppliers, and Vendors to enable such parties to perform functions on our behalf in order to carry out the purposes identified above, such as processing transactions, hosting our Site; analyzing our Site operations; improving the quality of our Site, business, products, and services; and otherwise helping us operate our business. We may disclose Personal Data with providers of online tracking technologies, as described below in the Cookies and Other Online Tracking Technologies section below.
  • Professional Advisors, including for performing audit functions and providing legal and other advice.
  • Corporate Transaction Parties, including any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of Hultec.
  • Parties in Relation to Legal Disclosures, Obligations, and Rights, including if required or authorized to do so by law or in the good-faith belief that such action is necessary to comply with legal obligations or with legal process; to comply with any subpoena, court order, governmental agency request, or other legal process; to protect our legal rights, property, or safety, or the rights, property, or safety of others; to exercise or defend legal claims; to comply with export control requirements; to investigate, prevent, or take action regarding actual or suspected illegal activities or fraud; to enforce our Terms and Conditions, this Privacy Notice, other policies, and our contractual agreements; and to prevent crime.

Cookies and Other Online Tracking Technologies

We and our vendors use cookies and other online tracking technologies (collectively, “Cookies”) on our Site to provide access to our Site; gather information about your usage patterns when you navigate our Site; enhance and personalize your experience; and improve our Site, products, and services.

Where permitted, we may engage web analytics service providers, such as Google Analytics, to help us understand and analyze how visitors interact with our Site. We use such data to administer and improve the quality of our Site. To learn more about the use of Cookies for Google analytics and to opt out of the use of such Cookies, please visit tools.google.com/dlpage/gaoptout.

Your web browser may have settings that allow you to transmit a “Do Not Track” signal when you visit various websites or use online services. Like many websites, our Site is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, visit allaboutdnt.com.

You may also set your browser to notify you of or decline Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.

Your Rights and Choices

If you no longer wish to receive our marketing communications or remain on our mailing list(s), you can opt out of such communications at any time. To unsubscribe, please follow the unsubscribe link in the relevant communication.

Subject to applicable privacy and data protection laws, you may have rights related to your Personal Data, including the rights to:

  • Request confirmation whether we process your Personal Data.
  • Request access to or information about your Personal Data that we collect, use, and/or disclose.
  • Request that your Personal Data be corrected, updated, and/or completed if you become aware that any Personal Data we hold about you is incorrect, out of date, or incomplete.
  • Request a copy of your Personal Data, including in an electronic format, and transmit such Personal Data to another entity under circumstances required by applicable law.
  • Object to or restrict our collection, use, disclosure, or other processing of your Personal Data under certain circumstances.
  • Withdraw your consent to process your Personal Data in circumstances where our collection, use, disclosure, or other processing is based on your consent; or request details about consequences for not consenting to a processing activity.
  • Request that we delete, destroy, anonymize, or block the processing of Personal Data that we have collected, used, disclosed, or otherwise processed about you.

We do not profile or use automated decision-making in a way that produces legal effects concerning you or otherwise significantly affects you.

If you wish to exercise any of your rights regarding your Personal Data or file a complaint, please submit a request to privacy@hultec.com. If you have any complaints about the processing of your Personal Data or our response to any rights request, we ask that you contact us; however, you also have the right to lodge a complaint with the relevant supervisory or other regulatory authority.

We may request specific information from you to help us confirm your identity prior to processing your request. Your rights are limited to the rights provided under the applicable law, which may be based on your country of residence, employment, and/or citizenship. Your rights can be restricted by exemptions permitted under relevant laws. If we deny your request, in whole or in part, which we are permitted to do under various applicable laws, we will explain why.

Safeguards

We maintain reasonable technical, organizational, and administrative measures to safeguard Personal Data against unauthorized and unlawful processing and and against misuse, accidental loss, unintentional destruction, or damage. However, no safeguarding measure is completely secure so we cannot guarantee the security of any Personal Data we have collected from or obtained about you.

External Websites

This Site contains links and references to other websites administered by unaffiliated third parties (“External Websites”). This Privacy Notice does not apply to such External Websites. When you click a link to visit an External Website, you will be subject to that External Website’s privacy practices. We encourage you to review the privacy policy of any linked External Websites before providing Personal Data on those External Websites. The inclusion of a link to another website or online service does not imply our endorsement.

Cross-Border Data Transfers

We transfer Personal Data to various jurisdictions for the purposes described above, including to the United States and other jurisdictions that may not provide the same level of data protection as your home country; and law enforcement agencies in the recipient countries may have access to your Personal Data. You acknowledge that your Personal Data may be processed in and further transferred to jurisdictions other than your own, including the United States. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers, including entering into the European Commission’s standard contractual clauses for transfers originating from the European Economic Area. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us as detailed below.

Personal Data Retention

We typically maintain Personal Data for as long as necessary to fulfill the purposes outlined in this Privacy Notice, and as otherwise permitted by applicable laws or regulations, including: where retention of your Personal Data is reasonably necessary to manage your relationship with us, carry out our operations, or satisfy another purpose for which we collected the Personal Data; to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Data was collected; or to protect or defend our rights or property.

Where Personal Data is used for more than one purpose, we will retain it until the purpose with the latest period expires.

Children

The Site is not intended for, nor targeted to, children under 18, and we do not knowingly collect or store Personal Data from anyone under the age of 18. If we are made aware that we have received Personal Data from someone under 18, we will remove that Personal Data in accordance with applicable law.

California Consumer Disclosures

This section is provided pursuant to the California Consumer Privacy Act (the “CCPA”) and applies to Personal Data we collect from California residents.

Unless otherwise noted, the disclosures in this California Privacy Notice apply to our current practices, as well as our activities in the 12 months preceding the effective date.

Collection, Use, and Disclosure of Personal Data

We collect, use, and disclose Personal Data as set out in the “Personal Data Collection,” “Personal Data Use,” and “Personal Data Disclosure” sections above. Additionally, we collect Personal Data described in Cal. Civ. Code § 1798.80(e), including Contact Information and Other Identifiers and Communications Contents, as described in the “Personal Data Collection” section.

We do not sell or share the Personal Data of California consumers, as “sell” and “share” are defined by the CCPA. We do not collect sensitive Personal Data from California residents.

California Privacy Rights

If you are a California resident, you have the following rights related to your Personal Data:

  • Request to know what Personal Data we have collected about you, including:
  • The categories of Personal Data we have collected about you;
  • The categories of sources from which the Personal Data is collected;
  • The business purpose for collecting Personal Data;
  • The categories of recipients to whom we disclose Personal Data; and
  • The specific pieces of Personal Data we have collected about you.
  • Request that we delete Personal Data we collected from you.
  • Request that we correct Personal Data we maintain about you that you believe is inaccurate.

If you wish to exercise any of your rights regarding your Personal Data, please submit a request to privacy@hultec.com or call +1 (817) 923-3344. We will not discriminate against you for choosing to exercise any of your California privacy rights.

Please note that when submitting a request, you may be asked to provide information so we can verify your identity before action is taken. You may designate an authorized agent to make the request on your behalf. An authorized agent must submit proof to us that they have been authorized by you to act on your behalf, and you may still need to verify your identity directly with us before we can process the request.

Changes to this Privacy Notice

We may update this Privacy Notice, as indicated by the “Last Updated” date at the beginning of this Privacy Notice. We will post updated versions of the Privacy Notice on our Site and take additional steps to notify you of updates as required by applicable law.

Contact Us

If you have questions or comments regarding this Privacy Notice or our privacy practices, please contact us at to privacy@hultec.com.

Hultec is the data controller and responsible for the processing of Personal Data we obtain. Hultec is located at 2170 Buckthorne Place, Suite 450, Spring, TX, 77380, United States.