Global Internet Privacy Policy

Ergotron Global Internet Privacy Policy

Ergotron, Inc. (“Ergotron”) recognizes and respects the privacy of our online visitors. It is Ergotron’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners, employees and others who share their Personal Information with us.

This Global Internet Privacy Policy (this “Policy”) applies to your Personal Information and describes how Ergotron, acting as the data controller, protects your privacy when we collect and use Personal Information on Ergotron sites. Unless stated otherwise, as used in this Policy, the term “Personal Information” means information that identifies you personally as a natural person, directly or indirectly, in combination with other information available to us such as an identification number, location data, online identifier or one or more factors specific to your identity as a natural person. Ergotron strives to adhere to the highest ethical standards in gathering, using, and safeguarding customers’ Personal Information. Unless indicated otherwise in another policy, this Policy applies, in general, to all internet sites owned by or on behalf of Ergotron and its business units as well as by our service providers, where any of those parties are either located within or outside the European Union and link to this Policy.

By using an Ergotron internet site or providing Personal Information to us, you understand the principles for our collection, use and disclosure of your Personal Information as described in this Policy.

Information We Collect

Information we may request includes your email address, name, home address, and telephone number(s). If you make a purchase, we may ask for your credit card number and other data to process your credit or financing request. For additional information regarding internet domain sites owned by Ergotron, please contact the legal department at the address listed below.

When We Collect Information

Examples of when we may ask you to provide Personal Information include, but are not limited to, when you:

• Use any internet domain sites owned by Ergotron;
• Request quotes, services, support, or information;
• Place orders for products or services;
• Register for an online account;
• Submit a product review, testimonial, comment, question, suggestion, or other content to us;
• Participate in surveys, sweepstakes, contests or other promotional activities;
• Subscribe to promotional emails, newsletters, or other materials;
• Apply for a job, submit your resume/CV, or create a candidate profile;
• Interact with our customer support chatbot, which is powered by Forethought. Forethought may collect, record, and store the Personal Information you provide in our chatbot. Please review Forethought’s privacy policy here; or,
• Contact us.

Personal Information may be collected by Ergotron and/or by our third-party service providers acting on our behalf and under our instructions in operating our internet sites and/or providing you with our products or services.

Why We Collect Information

We collect your Personal Information in order to conduct our business functions and operate our services, which include the following:

• communicating with you and providing you with information about products or services;
• providing you with our products and services as well as support in relation thereto;
• processing and managing your online account;
• processing and fulfilling your online order;
• processing returns, refunds and exchanges;
• conducting surveys, sweepstakes, contests or other promotional activities;
• promoting and marketing our products and services including, but not limited to, via promotional emails, newsletters or other materials;
• personalizing your experience on our internet sites or customizing any of our products or services;
• completing necessary financial transactions;
• performing recall actions;
• reviewing your job application;
• performing statistical analyses;
• complying with a legal requirement or court order; or
• defending, initiating or resolving disputes or legal proceedings and performing or enforcing the agreements to which Ergotron, or one of our business units, is a party.

We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is in accordance with this Policy or any agreement you enter into with us; or required or authorized by applicable law, including without limitation applicable privacy and data protection laws, including (EU) Regulation 2016/679 of 27 April 2016 (“EU GDPR”) and the UK Data Protection Act 2018 (“UK GDPR” and together with the EU GDPR referred to as the “GDPR”), the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., and in Canada, the Personal Information Protection Act (Alberta), Personal Information Protection Act (British Columbia), An Act Respecting the Protection of Personal Information in the Private Sector (Quebec), as applicable (“Canadian Privacy Laws”).

Sharing Personal Information

Ergotron will not sell Personal Information collected from its internet sites to mailing list brokers without your express consent.

Ergotron may share your Personal Information with other Ergotron business units. When doing so, these other Ergotron business units will use your Personal Information in a manner consistent with the purposes for which it was originally collected (or to which you subsequently consented) and only as permitted under this Policy, any applicable Country or Web Site Privacy Statements, and all applicable privacy and data protection laws.

Ergotron may also share your Personal Information with third parties we hire to perform support services for us. These third parties are required to use the Personal Information we share with them only to perform services on our behalf and under our instructions, and to treat your Personal Information as strictly confidential. In some cases, Ergotron may share your Personal Information with third parties who partner with us to provide products and services to our customers. If we do so, we will require our business partners to use the Personal Information we share with them in a manner consistent with the purpose for which it was originally collected (or to which you subsequently consented) and only as permitted under this Policy, any applicable Country or Web Site Privacy Statements, and all applicable privacy and data protection laws.

Ergotron may also share Personal Information publicly where you give us permission (e.g., product reviews).

In certain, limited circumstances, where permitted by applicable law, we may share or transfer Personal Information to unrelated third parties. For example, we may provide Personal Information to a third party (i) at your request; (ii) to comply with a legal requirement or court order; (iii) to investigate a possible crime, such as identity theft; (iv) in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of Ergotron or an Ergotron business unit; or (v) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your Personal Information.

Overseas Transfers and Disclosures

Some of your Personal Information may be transferred, stored, processed or used outside of the U.S.A. and/or outside of the European Union by Ergotron or by third-party service providers. This may happen if other Ergotron entities or venture partners are overseas, if we outsource certain activities overseas or if transactions, information, services or products have an overseas connection.

Your Personal Information may also be disclosed to third-party service providers which may store your Personal Information in the U.S.A. and European Union, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Policy.

Where required by applicable privacy and data protection laws, we take steps in order to ensure any overseas transfer of Personal Information is affected in compliance with the appropriate organizational and technical means (including e.g. EU Commission’s model clauses for data transfers or European Commission’s adequacy decisions). Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable privacy and data protection laws.

Cookies and Information Collected Via Our Sites

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Ergotron and our third-party advertising and analytics providers use cookies and similar technologies on our web sites to enable us to provide our products and services and help collect data about use of the sites, including traffic analysis, to record information about your activities on the web sites and to ‘remember’ you when you return to the Ergotron web site. Subject to their retention period as stated below, some cookies may remain on your computer until you delete them; others, like session ID cookies, may expire when you close your browser.

You can control cookies by configuring your browser to accept, restrict or reject all or certain cookies, or notify you when a cookie is sent to your browser. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. Cookies are browser specific; thus, if you use multiple devices or web browsers to access Ergotron web sites, you will need to manage your cookies preferences across these various devices and browsers. If you are using a mobile device to access Ergotron web sites, please refer to your instruction manual or other help/settings resource to find out how you can control cookies on your device. You may access Ergotron web sites even if you rejected all or certain cookies as described above; however, your ability to use some functionality and areas of the Ergotron web sites will be limited or the sites may not operate as intended and we might not be able to provide you with certain products or services. See the section “Online Tracking and Your Choices” below for more information on how the Ergotron web sites may respond to your browser settings. We do not control the use of cookies by third parties. See the section on “Third-party Advertisers and Analytics Providers” below and review the privacy policies of each of the third-party advertising and analytics providers for more information on third-party cookies.

For additional detail about how Ergotron processes information collected via our web sites, please see the Cookie Notice.

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and do not like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For more information, please view Hotjar’s privacy page by clicking here.

Third-Party Advertisers and Analytics Providers

Ads appearing on the Ergotron web sites may be delivered to users by third-party advertising providers, such as Google. We work with third-party advertising providers for purposes such as targeting our advertisements on the Ergotron web sites, and, in doing so we may share with those advertising providers, information about users’ use of the Ergotron web sites. We use third-party advertising and analytics providers, such as Google Analytics, to collect information about Ergotron web site usage and users of our sites, including demographic and interest-level information. Our advertising and analytics providers use cookies and Clear GIFs to collect demographic and interest-level information and usage information from users that visit the Ergotron web sites, including but not limited to information about the pages where users enter and exit the Ergotron web sites, what pages and advertisements users view and visit on the Ergotron web sites, and what items users purchase. Cookies and Clear GIFs allow advertisers and analytics providers to recognize a user when a user visits the Ergotron web sites, but also when a user visits other web sites. Our advertising and analytics providers use the information they collect from the Ergotron web sites and other web sites to profile users to display relevant advertising and to share with us and other web site operators information about users. We do not link information we receive from our analytics partners with personally identifiable information. For more information regarding Google’s use of cookies and collection and use of information see the Google Privacy Policy. If you would like to opt out of Google Analytics tracking, please go to Google Analytics and change your preferences accordingly.

Online Tracking and Your Choices

As discussed above, we track web site usage information through using cookies, Clear GIFs, and other tracking mechanisms. You can manage the settings on your browser or mobile device to delete and disable cookies and other tracking/recording tools. Doing so may impact your experience using the Ergotron web sites and may make certain features and areas unavailable to you. Many advertising companies are also members of the NAI or DAA and provide opt-outs on those industry pages at www.networkadvertising.org/choices and www.aboutads.info/choices.

Security

We maintain commercially reasonable security measures to protect the Personal Information we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee absolute security.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Ergotron web sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

Links to Third-Party Web Sites

Ergotron web sites may contain links to web sites that are not owned by Ergotron. These links are provided as a convenience and do not imply any endorsement of the activities or content of these sites, nor any association with their operators. Ergotron does not control these web sites and is not responsible for the content, security, or privacy practices of these web sites and their owners. We urge you to review the privacy policy posted on these web sites you visit before using the site or providing Personal Information.

Retention of Personal Information

Ergotron may retain the Personal Information collected on Ergotron web sites as long as necessary to provide the services, products and information you request or as mandated or permitted by applicable law (e.g., statute of limitations). If your Personal Information is no longer necessary for purposes for which it is processed and we have no legal obligation to retain that Personal Information, we will remove it from our systems and destroy all record of it.

Children and Parents

Ergotron does not knowingly solicit or collect Personal Information from or about children on its web sites except as permitted under applicable law. If you are under 18 years of age, please do not submit any Personal Information through our web sites without the express consent and participation of a parent or guardian. If your child has submitted Personal Information and you would like to request that such Personal Information be deleted from our records, you may do so by contacting us at the address listed in the “Contacting Us” section below.

Choices about Your Personal Information

Review and Request Changes to Your Personal Information

You may use your account to access, correct, or view certain Personal Information we have collected, and which is associated with your account. To review or request changes to any of your Personal Information, please contact us as described in the “Contacting Us” section below.

Marketing Communications

To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us as described in the “Contacting Us” section below.

Your Rights – European Union and United Kingdom Only

If you are an individual whose data is processed by an EU/UK Ergotron entity or whose processing is otherwise subject to GDPR, the following applies to you:

Right to Access Personal Information

You are entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you access to your Personal Information. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with reasons for the refusal where we are required by law to give those reasons.

Right to Correct Personal Information

You can access and correct some of your Personal Information through our web sites by contacting us via telephone or email using the details provided below.

We take all reasonable steps to ensure that any Personal Information we collect, and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete Personal Information about yourself as requested, and properly update the Personal Information provided to us to keep it true, accurate, current and complete. Please tell us, by contacting us in any of the ways specified in this Policy, if any change occurs in the Personal Information you provided us or, if you believe that your Personal Information is inaccurate or incomplete, and we will correct the information.

Right to Restrict Our Use of Personal Information

You have the right to ask us to place a restriction on our use of your Personal Information if one of the following applies to you:

• You contest the accuracy of the information that we hold about you, while we verify its accuracy;
• We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
• We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
• You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

Right to Object to Our Use of Personal Information

You have the right to object to our use of your Personal Information where our reason for using it is based on our legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us).

Right to Request Deletion of Personal Information

You can ask us to delete your Personal Information if:

• We no longer need it for the purposes for which we collected it;
• We have been using it with no valid legal basis;
• We are obligated to erase it to comply with a legal obligation to which we are subject;
• We need your consent to use the information and you withdraw your consent;
• You object to us processing your Personal Information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities.

If you do exercise a valid right to have your Personal Information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Right to Transfer Your Personal Information

You have the right to ask for a copy of your Personal Information and/or ask for it to be ported to another provider of your choice where the lawful basis for the processing is (i) (a) a contract or (b) your consent and (ii) by automated means. Please note that such a request could be limited solely to the Personal Information you provided to us or that we hold at that given time, and subject to any relevant legal requirements and exemptions, including identity verification procedures.

Right to Make a Complaint

If you have any concerns or complaints regarding our processing of your Personal Information, please contact us as described in the “Contacting Us” section below and we will do our best to answer any question and resolve any complaint to your satisfaction. If you are not satisfied with our answer or the way we process your Personal Information pursuant to this Policy, you may also have the right to lodge a complaint with a data protection authority or the competent court. If you reside within the European Union, European Economic Area, or United Kingdom, a list of national data protection authorities can be found here and here.

Limitations on the Collection, Use and Disclosure of Personal Information

To the extent required by applicable European law, whenever Ergotron collects Personal Information on an Ergotron web site, Ergotron will:

• Collect, use, disclose and transfer your Personal Information only with your consent when required, depending on the sensitivity of the Personal Information, legal requirements, direct marketing by third parties and other factors. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal;
• Collect your Personal Information only for specific, limited and legitimate purposes. This information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
• Process your Personal Information in a manner consistent with the purpose for which it was originally collected or to which you have subsequently consented;
• Take commercially reasonable steps to ensure that your Personal Information is reliable for its intended use, accurate, complete, and, where necessary, and subject to your updates, kept up to date;
• Not use your Personal Information for direct marketing purposes by Ergotron without giving you an opportunity to “opt-out”; and,
• Take appropriate measures, by contract or otherwise, to provide adequate technical and organizational protection for Personal Information that we collect and use, and for Personal Information that is disclosed to a third party or transferred to another country, including transfers within Ergotron.

Legal Basis for Processing Your Personal Information

The legal basis for collecting and using your Personal Information will depend on the Personal Information concerned and the specific context in which we collect it, which is discussed below.

Notice to Nevada Residents

Nevada law allows Nevada residents to opt-out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales and we will record your instructions and incorporate them in the future if our policy changes. Opt-out requests may be sent to [email protected].

Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified, or aggregated information, or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section, we will refer to this information as “Personal Information.”

If you are California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your Personal Information in that capacity.

Collection of Personal Information

We currently collect and, in the 12 months preceding the “last revised” date of this Policy, have collected the following categories of Personal Information:

• Identifiers (name, postal address, online identifier, Internet Protocol address, email address)
• Unique personal identifiers (cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology; customer number, unique pseudonym, or user alias)
• Telephone number
• Credit card number (processed through Digital River)
• Internet or other electronic network activity information (information regarding consumer’s interaction with website, application, or advertisement)
• Geolocation data
• Commercial information (records of products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies)
• Professional or employment-related information (e.g., company name and address)
• Audio, electronic, or visual information (e.g., product reviews)

We collect Personal Information directly from California residents, data brokers, operating systems and platforms, and data analytics providers. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “Why We Collect Information,” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Auditing related to counting ad impressions to unique visitors
• Helping to ensure security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, non-personalized advertising
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytic services, or providing similar services
• Providing advertising and marketing services (except for cross-context behavioral advertising)
• Undertaking internal research for technological development and demonstration
• 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
• Enabling or effecting, directly or indirectly, a commercial transaction

Sale, Sharing, and Disclosure of Personal Information

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the “last revised” date of this Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

We sold or shared Personal Information for the following business and commercial purposes:

• Auditing related to counting ad impressions to unique visitors
• Providing advertising and marketing services
• Enabling or effecting, directly or indirectly, a commercial transaction

We do not knowingly collect, sell, or share the Personal Information of minors under 16 years of age.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the “last revised” date of this Policy and, for each category, the categories of recipients to whom we disclosed Personal Information:

We disclosed Personal Information for the following business or commercial purposes:

• Helping to ensure security and integrity
• Debugging to identify and repair errors that impair existing intended functionality
• Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services
• Providing advertising and marketing services (except for cross-context behavioral advertising)
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality or safety of a service or device

We do not use or disclose Sensitive Personal Information for purposes other than those the CCPA and its regulations allow for.

To learn more about our online and offline practices regarding the retention of Personal Information, please see our “Retention of Personal Information” section above.

Your Rights – California Residents

If you are a California resident, you have the following rights with respect to your Personal Information:

1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling, or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
3. The right to correct inaccurate Personal Information that we maintain about you;
4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct through our interactive web form, by emailing [email protected], or by calling us toll free at 1-800-888-8458. If you submit a request to delete online, you may be asked to confirm separately that you want your Personal Information deleted.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

If we determine that your request is not subject to an exemption or exception, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable.

For requests to know categories of Personal Information and for requests to delete or correct Personal Information that is not sensitive and does not pose a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

For requests to know specific pieces of Personal Information or for requests to delete or correct Personal Information that is sensitive and poses a risk of harm by unauthorized deletion or correction, we will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information you previously provided to us and which we have determined to be reliable for the purpose of verifying identities. In addition, you must submit a signed declaration under penalty of perjury stating that you are the individual whose Personal Information is being requested.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct businesses to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing by clicking on this link: “Do Not Sell or Share My Personal Information.” You also may submit a request by emailing [email protected], or by calling us toll free at 1-800-888-8458. If you have enabled privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Shine the Light Law

We do not disclose personal information obtained through our web sites or services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

Notice to Canadian Residents

If you are an individual in Canada, the following applies to you:

Purposes for Collecting, Using, and Disclosing Your Personal Information

The purposes for collecting and using your Personal Information will depend on the Personal Information concerned and the specific context in which we collect it, which is discussed below.

Consent

We will ask for consent to collect, use, or disclose (“Process”) Personal Information, except in circumstances where collection, use or disclosure of Personal Information without consent is authorized by Canadian Privacy Laws. Subject to Canadian Privacy Laws, we may deem consent to be implied in cases where you volunteer information for an obvious purpose.

You may withdraw your consent to the use and disclosure of Personal Information at any time, unless the Personal Information is necessary to fulfill our legal obligations. The withdrawal of your consent to the use and disclosure of Personal Information may mean that we will not be able to continue a commercial relationship or provide certain products and services if it does not have the necessary Personal Information.

Use and Disclosure of Personal Information

We will use and disclose Personal Information only for the purposes for which the information was collected (including those described below), except as otherwise authorized by Canadian Privacy Laws. If we wish to use or disclose Personal Information for a new purpose, we will ask for consent, unless consent is not required by Canadian Privacy Laws.

We may, from time to time, transfer Personal Information to our affiliates located in other provinces or countries, including the United States of America (US). Such affiliates may receive, process and handle Personal Information for the purposes described in this Policy and will provide a level of protection for Personal Information that is comparable to that provided by us.

Additionally, we may disclose Personal Information to third-party service providers, including third-party service providers located in Canada or the United States of America (US), for the purposes of providing services or functions on behalf of the Company (e.g., employment verification services). Personal Information will only be disclosed to such third-party service providers in accordance with this Policy and as required under Canadian Privacy Laws. The Company will endeavor to ensure that its contracts with third-party service providers limit the retention, use and disclosure of Personal Information by the third-party service provider solely for the purpose of carrying out the contracted services and provide a level of protection for Personal Information that is comparable to that provided by the Company.

Protecting Personal Information

We will protect Personal Information in a manner appropriate to the sensitivity of the information. We will make every reasonable effort to prevent loss, misuse, disclosure, copying, modification, disposal or destruction of Personal Information or any unauthorized access to Personal Information. Employee access to Personal Information is limited to those employees who require such Personal Information to carry out their duties. We will retain Personal Information only for as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes and will employ appropriate measures to render Personal Information non-identifying or destroy Personal Information.

Ensuring Accuracy

We use reasonable efforts to ensure that Personal Information is kept as accurate, complete and up to date as possible. We do not routinely update Personal Information, unless such an update is necessary. To help us maintain and ensure that your Personal Information is accurate and up to date, you must inform us, without delay, of any change in the information you provide to us.

Your Rights – Canadian Residents

Depending upon the province in which you reside, you may benefit from any or all of the following rights:

1. Access: You have the right to request whether we hold Personal Information on you and to request a copy of such information. To do so, please contact us at the coordinates provided below. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal Personal Information about another person, or if we are legally prevented from disclosing such information.
2. Accuracy: We aim to keep your Personal Information accurate, current, and complete. We encourage you to contact us at the coordinates provided below to let us know if any Personal Information is not accurate or changes, so that we can update your Personal Information.
3. Cessation of Dissemination (Quebec residents only): You have the right to request that we cease disseminating your Personal Information if the dissemination is contrary to the law or a court order. You also have the right to request that we cease disseminating your Personal Information where the following conditions are met:
   1. the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
   2. the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and
   3. the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.
4. De-indexation (Quebec residents only): You have the right to request that we de-index any hyperlink attached to your name that provides access to information by a technological means if the dissemination is contrary to the law or a court order. You also have the right to request that we de-index a link providing access to information where the following conditions are met:
   1. the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;
   2. the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and
   3. the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.
5. Re-indexation (Quebec residents only): You have the right to request that we re-index a link providing access to information where the following conditions are met:
   1. a failure to do so causes you serious injury in relation to your right to have your reputation or privacy respected;
   2. the injury caused by a failure to re-index is greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and
   3. the re-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury.
6. Mobility (Quebec residents only): You have the right to request that computerized Personal Information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such information. This right does not extend to information that was created or inferred from your Personal Information and we are under no obligation to communicate such information if doing so raises serious practical difficulties.
7. Complaints: If you believe that your Personal Information protection rights may have been violated, you have the right to lodge a complaint with the applicable supervisory authority, or to seek a remedy thought the courts.

At any time, you may exercise any of the above rights by contacting us at the coordinates provided below. We will generally respond to the above requests within 30 days of the receipt of all necessary information. In circumstances where we are not able to provide access, or if additional time is required to fulfill a request, we will advise you in writing. If we are forbidden from releasing certain types of information based upon exemptions specified in applicable laws, where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions.

In certain circumstances, such as where the request is excessive or unfounded, we may charge you an administration fee for access to your Personal Information. We may also charge for additional copies. We will advise you of any fees before proceeding with a request.

You may learn more about the process or obtain assistance in completing an access request by contacting us at the coordinates provided below.

Resolution of Concerns

Any report, concern, complaint or incident of which we become aware that involves conduct that may contravene this Policy will be treated confidentially to the extent possible. However, some disclosure may be necessary to adequately address issues raised, aid enquiry and implement solutions, as appropriate.

We take all potential or actual Personal Information breaches seriously. You may report your concerns about the Processing of your Personal Information directly to us at the coordinates provided below. We will engage the appropriate levels of management to assist with resolution of the issue.

While we are committed to resolving all Personal Information matters internally, nothing in this Policy precludes you from contacting the appropriate federal or provincial privacy commissioner.

We will not retaliate against a person who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their Personal Information.

Roles and Responsibilities

We are responsible for communicating the Policy and ensuring that employees fully comply with all relevant aspects of the Policy and the accompanying guidelines.

Business or infrastructure units that Process Personal Information other than as required, are responsible for ensuring that these activities comply with the Policy.

Our Chief Privacy Officer is responsible for:

1. developing our Personal Information protection strategy;
2. developing and maintaining the Policy, accompanying guidelines and any other policy or procedure related to Personal Information and ensuring they comply with applicable law;
3. serving as the official liaison with the federal and provincial privacy commissioners.

Changes to this Policy or our Privacy Statements

We reserve the right to update or modify this Policy at any time and without prior notice by posting the revised version of this Policy on our Ergotron web sites. Where such changes are substantial, we notify you of the expected changes prior to their entry into force.

Accessibility

We are committed to ensuring this Policy is accessible to individuals with disabilities. If you wish to access this Policy in an alternative format, please contact us as described below.

Contacting Us

If you would like to contact us for any reason regarding our privacy practices and/or would like to discontinue our use of your Personal Information, please write to us at the following address: