BINDING CORPORATE RULES Page 1 of 13 EcoServices, LLC 100 Great Meadow Rd, Suite 202 Wethersfield, CT 06109 (T) (+1)860-466-4900; (F) (+1)860-466-4899 www.ecopower.aero The Clear Solution for Cleaner Engines ECOSERVICES, LLC BINDING CORPORATE RULES A. INTRODUCTION EcoServices respects the legitimate privacy interests of the people from whom it Processes Personal Information, such as its managers, officers, employees, contractors, customers, suppliers, and vendors. EcoServices has adopted Binding Corporate Rules (“BCRs”) for the Personal Information that it Processes about Individuals. EcoServices Corporate Office (the U.S. headquarters), has responsibility for remedying breaches of the BCRs. Exhibit A provides definitions for terms and acronyms used in these BCRs. EcoServices transfers Personal Information including human resources information (employees and leased labor); business contact information for business customers, suppliers, vendors, sales representatives, and other business partners; information from consumers of EcoServices products, generally warranty information and limited information, such as name and address, on consumers who have a service contract with EcoServices; information on visitors and non-employee sales representatives and distributors; and information collected for the use of EcoServices products and services by users of those products and services. Personal Information is transferred within EcoServices depending on the products and services provided and the support required for particular services or projects. The bulk of Personal Information is transferred to the EcoServices Corporate Office, located in the U.S. B. APPLICABILITY 1. These BCRs are mandatory for all EcoServices’ entities and individuals. All entities shall ensure that their Personnel comply with these BCRs when Processing an Individual’s Personal Information. EcoServices will establish clear and consistent controls across the enterprise to ensure compliance with the BCRs. 2. At a minimum, EcoServices will comply with all laws and regulations related to the protection of Personal Information applicable to it worldwide. Provisions of local laws, regulations, and other restrictions applicable to EcoServices that impose a higher level of data protection shall have precedence over the BCRs. If applicable law conflicts with these BCRs
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BINDING CORPORATE RULES
Page 1 of 13 EcoServices, LLC 100 Great Meadow Rd, Suite 202 Wethersfield, CT 06109 (T) (+1)860-466-4900; (F) (+1)860-466-4899
www.ecopower.aero The Clear Solution for Cleaner Engines
ECOSERVICES, LLC
BINDING CORPORATE RULES
A. INTRODUCTION
EcoServices respects the legitimate privacy interests of the people from whom it Processes
Personal Information, such as its managers, officers, employees, contractors, customers,
suppliers, and vendors.
EcoServices has adopted Binding Corporate Rules (“BCRs”) for the Personal Information that
it Processes about Individuals. EcoServices Corporate Office (the U.S. headquarters), has
responsibility for remedying breaches of the BCRs.
Exhibit A provides definitions for terms and acronyms used in these BCRs.
EcoServices transfers Personal Information including human resources information
(employees and leased labor); business contact information for business customers, suppliers,
vendors, sales representatives, and other business partners; information from consumers of
EcoServices products, generally warranty information and limited information, such as name
and address, on consumers who have a service contract with EcoServices; information on
visitors and non-employee sales representatives and distributors; and information collected for
the use of EcoServices products and services by users of those products and services. Personal
Information is transferred within EcoServices depending on the products and services
provided and the support required for particular services or projects. The bulk of Personal
Information is transferred to the EcoServices Corporate Office, located in the U.S.
B. APPLICABILITY
1. These BCRs are mandatory for all EcoServices’ entities and individuals. All entities shall
ensure that their Personnel comply with these BCRs when Processing an Individual’s
Personal Information. EcoServices will establish clear and consistent controls across the
enterprise to ensure compliance with the BCRs.
2. At a minimum, EcoServices will comply with all laws and regulations related to the
protection of Personal Information applicable to it worldwide. Provisions of local laws,
regulations, and other restrictions applicable to EcoServices that impose a higher level of data
protection shall have precedence over the BCRs. If applicable law conflicts with these BCRs
BINDING CORPORATE RULES
Page 2 of 13 EcoServices, LLC 100 Great Meadow Rd, Suite 202 Wethersfield, CT 06109 (T) (+1)860-466-4900; (F) (+1)860-466-4899
www.ecopower.aero The Clear Solution for Cleaner Engines
in that it might prevent EcoServices’ Corporate Office or one or more of its branch operations
from fulfilling their obligations under the BCRs and has a substantial effect on the guarantees
provided therein, the entity concerned shall promptly notify the EcoServices General Counsel,
except where providing such information is prohibited by a law enforcement authority or law.
The EcoServices General Counsel shall determine the appropriate course of action and, in
case of doubt, consult with the competent data protection authority.
3. In case of a conflict between these BCRs and EcoServices Data Privacy Policy, DP-001,
these BCRs prevail for Personal Information originating directly or indirectly from the
European Economic Area or Switzerland.
C. SCOPE
These BCRs govern the Processing by EcoServices of Personal Information of Individuals
wherever located, except that (i) the requirement to obtain explicit consent for Sensitive
Personal Information, (ii) the provisions contained in Section D.6, paragraphs 1 through 6
regarding the enforcement rights of individuals and guarantees, (iii) Section B.4 relating to
discrepancies between the BCRs and DP-001, and (iv) the part of Section D.1(f) relating to
sharing of data with law enforcement and regulatory authorities, shall only apply to Personal
Information originating directly or indirectly from the European Economic Area or
Switzerland.
D. POLICY
1. Privacy Principles: In all of its activities, EcoServices shall:
a) Process Personal Information fairly and lawfully
Individuals’ Personal Information shall be Processed for identified purposes (1) on the basis
of consent; (2) when required or permitted by law in the country of origin, or (3) for a
legitimate purpose, such as human resources management, business interactions with
customer and supplier, and a threat of physical harm.
Individuals’ Sensitive Personal Information shall only be Processed when: (1) required by law
in the country of origin of the data; (2) with the explicit consent of the Individual where
permitted by law; or (3) when necessary to protect the vital interests of the Individual or the
establishment, exercise, or defense of a legal claim by EcoServices.
BINDING CORPORATE RULES
Page 3 of 13 EcoServices, LLC 100 Great Meadow Rd, Suite 202 Wethersfield, CT 06109 (T) (+1)860-466-4900; (F) (+1)860-466-4899
www.ecopower.aero The Clear Solution for Cleaner Engines
Individuals’ Personal Information shall not be Processed for any incompatible purposes unless
allowed under one of the conditions set out in the immediately preceding paragraph, for
example, by obtaining a new consent.
b) Only Process Personal Information that is relevant
EcoServices shall make efforts to ensure that the Processing of Individuals’ Personal
Information is adequate, relevant and not excessive in relation to the purpose or purposes for
which the information is Processed. In addition, EcoServices will not keep Individuals’
Personal Information for longer than necessary for the purpose(s) for which it was collected,
unless with consent when used for a new purpose or otherwise required by applicable law,
regulation, court proceedings, administrative proceedings, arbitration proceedings, or audit
requirements. EcoServices will make efforts to ensure that the Individuals’ Personal
Information in its possession is accurate and current.
c) Provide appropriate notice to Individuals whose Personal Information EcoServices
Processes
Unless the Individual is already aware of this information, EcoServices shall, at the time of
collecting Personal Information, provide notice to Individuals of the Personal Information that
is to be collected; the EcoServices entity responsible for the collected Personal Information;
the purpose(s) for which that Personal Information is to be collected; third parties with whom
EcoServices will share the information; the choices and rights provided to Individuals; the
means for limiting collection, use, and disclosure of Personal Information, and the
consequences of those choices; and how to contact EcoServices with questions or complaints
about privacy matters. In exceptional cases, where providing this notice presents a
disproportionate burden (where the Personal Information was not obtained from the
Individuals themselves), EcoServices may, after careful consideration, decide not to provide
notice to Individuals or to postpone providing notice.
d) Respect the legitimate privacy rights of Individuals to request access to and rectification of
their Personal Information
EcoServices shall allow Individuals to request access to and rectification of their Personal
Information. EcoServices will comply with requests in a reasonable period of time, provided
such requests are not manifestly unfounded or excessive. EcoServices shall bear the burden of
demonstrating the manifestly unfounded or excessive character of the request. Individuals
may be required to provide proof of their identity and may be subject to a servicing fee as
permitted by applicable law.
On compelling legitimate grounds, Individuals may object to the Processing of their Personal
Information or request the blocking or erasure of their Personal Information. EcoServices will
BINDING CORPORATE RULES
Page 4 of 13 EcoServices, LLC 100 Great Meadow Rd, Suite 202 Wethersfield, CT 06109 (T) (+1)860-466-4900; (F) (+1)860-466-4899
www.ecopower.aero The Clear Solution for Cleaner Engines
comply with such requests, unless retention of Personal Information is required by contractual
obligations, audit requirements, regulatory or legal obligations, or to defend the company
against legal claims. Individuals will be informed of the consequences that may arise as a
result of their choice to have EcoServices not Process their Personal Information, such as the
inability of EcoServices to provide a requested service or enter into a transaction. Individuals
will also be informed about the outcome of their request.
With the exception of those Individuals who have elected not to receive certain
communications and in accordance with applicable law, EcoServices may Process
Individuals’ Personal Information to target communications to Individuals based on their
interests. Individuals who do not wish to receive marketing communications from
EcoServices will be offered easily accessible means to oppose further advertising, for
example, in their account settings or by following the directions provided in an email or from
a link in the communication. When in doubt about the application of anti-spam regulations,