NOTICE OF PRIVACY PRACTICES

LAST UPDATED: FEBRUARY 15, 2019

Leatherman Europe GMBH (registered at Holterkamp 16 40880 Ratingen, Germany) is the data controller of personal data collected and processed through the Leatherman Europe website. Leatherman Europe (“Leatherman,” “we,” “our,” or “us”) recognizes that you care about how information about you is used and shared. This notice of our privacy practices (the “Notice”) informs you of how personal data is collected on and through this Leatherman website, located at http://www.leatherman.com/de (the “Website”), how we may use the information and with whom we may share it. This Notice also describes (i) the measures we take to safeguard personal data we collect and (ii) your rights concerning our collection, use and disclosure of personal data about you.

Updates to this Notice. We may update this Notice to provide clarification or notice of changes to our practices from time to time. If we make changes, we will revise the “Last Updated” legend at the top of this Notice. Any material changes to this Notice will be posted on the Website and we encourage you to check back from time to time to ensure continuing familiarity with the most current version of the Notice.

General Audience Website. Services offered by Leatherman are not directed to individuals under the age of sixteen (16). Leatherman does not knowingly collect personal information (as defined below) from individuals under sixteen (16) years of age. No information should be submitted to or posted to the Website by visitors younger than sixteen (16).

INFORMATION WE COLLECT

We collect your personal data from you, for example through our Website, when you create accounts with us, when you purchase our products, or when you contact customer service. You can choose not to provide certain information but then you may not be able to take advantage of functionalities on the Leatherman Website. Personal data that we collect about you may include:

  • Contact Information that allows us to communicate with you, such as your name, job title, age, date of birth, prefix and title, gender, username, mailing address, telephone numbers, email address or other addresses.
  • Relationship Information that helps us do business with you, such as the types of products and services that may interest you, contact and product preferences, languages, marketing preferences, demographic information, photos and videos, and surveys and questionnaires completed in relation to Leatherman products or services.
  • Transaction Information about how you interact with us, including purchases, inquiries, account information, order and contract information, delivery details, billing and financial information, and information about how you use and interact with our websites.
  • Security and Compliance Information that helps us to secure our and your interests, including information and documents for identity verification and fraud prevention.
  • Technical Information collected by our website. When you visit and use our website, our web server generates log files that contains IP addresses, type of browser or operating system, date and time you access our website, and login information. Our Website also uses cookies that may collect additional information about you; for further information please see our Cookies Page.

Google Analytics
Our website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify users or associate your IP address with any other data held any Google. We use reports provided by Google Analytics to help us understand website traffic and webpage usage. Read more about how Google uses data when you use our site: https://policies.google.com/privacy/partners

How do we secure your personal data?
We apply appropriate technical, physical and organizational measures that are reasonably designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where personal data is transferred over a network, and against all other unlawful forms of processing. Access to personal data is restricted to authorized recipients as appropriate. We maintain comprehensive information security safeguards that are proportionate to the risks associated with the processing. We continuously adapted these safeguards to mitigate operational risks and to ensure the protection of your personal data taking into account industry-accepted practices. We also use enhanced security measures such as encryption when processing certain personal data.

How We May Use the Information We Collect
We use your personal data to provide and improve our products and services, which includes the following purposes:

  • Fulfilling your orders for products or services and related activities, such as product and service delivery, customer service, account and billing management, support and training, and other services related to your purchase.
  • Managing your ongoing relationship with us, including interacting with you, informing you about our products or services, improving our products and services, informing you about special offers and promotions, and providing you with interest-based advertisements.
  • Ensuring the security and usability of our websites, networks and systems, and premises, as well as for fraud prevention purposes.
  • Managing our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, fulfillment, corporate governance, audit, reporting and compliance with internal policies.
  • Complying with legal obligations, such as to protect against any prohibited or illegal activity, comply with applicable law, and establish, exercise and defend a legal claim.

These processing operations are based on the following legal bases, as applicable, set forth in the EU General Data Protection Regulation (“GDPR”): (i) the need to enter into or fulfill a contract with you (Art. 6(1)(b) GDPR), (ii) our legal obligations (Art. 6(1)(c) GDPR), (iii) our legitimate business interests (Art. 6(1)(f) GDPR), and (iv) in specific circumstances, your consent (Art. 6(1)(a) GDPR).

How do we secure your personal data?
We apply appropriate technical, physical and organizational measures that are reasonably designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where personal data is transferred over a network, and against all other unlawful forms of processing. Access to personal data is restricted to authorized recipients as appropriate. We maintain comprehensive information security safeguards that are proportionate to the risks associated with the processing. We continuously adapted these safeguards to mitigate operational risks and to ensure the protection of your personal data taking into account industry-accepted practices. We also use enhanced security measures such as encryption when processing certain personal data.

Who do we disclose your personal data to?
We share your personal data to provide and improve our products and services, to the following:

  • Third party service providers to provide or perform services and functions on our behalf. We may share your personal data, as necessary, to perform these services and functions. Any access to that personal data will be limited to the purposes for which the information was provided.
  • Public or judicial authorities and agencies as required by law. We may also disclose information to third parties, including legal counsel, when necessary for the establishment, exercise or defense of legal claims or to otherwise enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed to support audit, compliance and corporate governance functions.
  • Third parties involved in business transfers. We may disclose your personal data to a party acquiring all or part of the equity or assets of Leatherman or its business operations in the event of a sale, merger, liquidation, dissolution, or sale or transfer of the substantial assets of Leatherman or any of its business operations. We may also transfer and share such information to our affiliates within the group, in accordance with applicable law.

Do you transfer personal data out of the European Economic Area (EEA)?
We may transfer your personal data out of the EEA to countries that have not been determined by the European Commission to provide an adequate level of data protection. In any such transfer, we will ensure that appropriate data protection safeguards such as Standard Contractual Clauses are in place, or that you have consented to such transfer. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please contact us using the contact information below.

What are my options and rights in relation to my personal data?
You have the right to:

  • Request access to your personal data.
  • Request that your personal data is corrected, deleted, transmitted to another person, or restricted.
  • Withdraw any consent you have provided to our processing of your personal data.
  • Object to our processing of your personal data for any purpose, including direct marketing.

Please contact us using the contact information below if you wish to exercise any of these rights. Before processing your requests, we may ask you to provide information to verify your identity. In certain situations, and subject to applicable law, we may not be able or obliged to grant part or all of your request. We have the right to refuse and/or charge a monetary fee for requests which are manifestly unfounded or excessive, for example because of their repetitive character. You have the right under applicable data protection law to file a complaint with the relevant data protection authority.

Opting Out of Direct Marketing
You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in our marketing emails, adjusting your email preferences via the hyperlink provided on the “My Account” page on the Website, or by contacting us as specified in the “How to Contact Us” section below. You may still receive service oriented, administrative communications from us as you cannot opt-out of receiving such administrative communications.

Links
This Website may contain links to websites or web pages not operated by Leatherman. Once you leave the Website, we suggest that you review the applicable privacy policy of the third party website regarding, among other things, how they will handle any personal information they collect from you. We are not responsible for the content of any websites that are not affiliated with Leatherman, any use of those websites, or the privacy practices of those websites.

How long do we keep your personal data?
We keep your personal data for as long as necessary for the purposes described in this Privacy Notice or as permitted under applicable law. We also keep your personal data as required under applicable retention policies or as otherwise communicated to you (for example, we may keep your transaction history so you can review past purchases).

Updates to this Privacy Notice
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal data practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Notice. You should also check this page from time to time to ensure that you are happy with any changes.

How to Contact Us
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily or have any questions or comments about this Notice, or if you would like us to update information we have about you or your preferences, please contact us by email at info-europe@leatherman.com

You also may write to us at:
Leatherman Europe GmbH
Holterkamp 16
40880 Ratingen, Germany
info-europe@leatherman.com