Data Privacy Framework Policy

Enerpac Tool Group Corp., and each of its related U.S. subsidiaries (i.e., Hydratight Operations, Inc.; Cortland Company, Inc.; Engineered Solutions, L.P.; Enerpac Tool Group Corp. (“EDC”); and Biach Industries) (hereafter referenced as “Enerpac Tool Group,” “we,” “our,” and “us”), complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Enerpac Tool Group has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Definitions
“Enerpac Tool Group” means Enerpac Tool Group as well as each of its related subsidiaries, business units and other legal entities. The subsidiaries, business units and/or other legal entities are: Biach, Cortland, Enerpac, Equalizer International, HTL Group, Hydratight, Larzep Hydraulic, Mirage, Simplex, and Sweeney.

“Data Subject” means the individual to whom any given Personal Data covered by this DPF Policy refers.

“Personal Data” means any information relating to an individual residing in the European Union that can be used to identify that individual either on its own or in combination with other readily available data.

“Sensitive Personal Data” means Personal Data regarding an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, physical or mental health, or sexual life.

Scope and Responsibility
This DPF applies to Personal Data transferred from European Union member countries and the UK to Enerpac Tool Group’s operations in the U.S. in reliance on the respective DPF and does not apply to Personal Data transferred under Standard Contractual Clauses or any approved derogation from
the EU Directive. Enerpac Tool Group has also entered into Standard Contractual Clauses for the transfer of Personal Data, which is documented in a separate document.

Some types of Personal Data may be subject to other privacy-related requirements and policies. For example:

• Some Enerpac Tool Group websites have their own privacy policies.

• Personal Data regarding and/or received from a client is also subject to any specific agreement with, or notice to, the client, as well as additional applicable laws and professional standards.

• Employee Personal Information is subject to internal human resource policies including the Enerpac Tool Group Privacy Notice.

All employees of Enerpac Tool Group that have access in the U.S. to Personal Data covered by this DPF Policy are responsible for conducting themselves in accordance with this DPF Policy. Adherence by Enerpac Tool Group to this DPF Policy may be limited to the extent required to meet legal, regulatory, governmental, or national security obligations, but Personal Data covered by this DPF Policy shall not be collected, used, or disclosed in a manner contrary to this policy without the prior written permission of Enerpac Tool Group’s Executive Vice President – HR.

Enerpac Tool Group employees responsible for engaging third parties to which Personal Data covered by this DPF Policy will be transferred are responsible for obtaining appropriate assurances that such third parties have an obligation to conduct themselves in accordance with the applicable provisions of this DPF Principles, including any applicable contractual assurances required by DPF.

DPF Principles
Enerpac Tool Group commits to subject to the DPF’s Principles all Personal Data received by Enerpac Tool Group in the U.S. from European Union member countries and the UK in reliance on the respective DPF framework, for both HR and Non-HR data.

1. Notice
Enerpac Tool Group notifies Data Subjects covered by this DPF Policy about its data practices regarding Personal Data received by Enerpac Tool Group in the U.S. from European Union member countries and the UK in reliance on the respective DPF framework, including the types of Personal Data it collects about them, the purposes for which it collects and uses such Personal Data, the types of third parties to which it discloses such Personal Data and the purposes for which it does so, the rights of Data Subjects to access their Personal Data, the choices and means that Enerpac Tool Group offers for limiting its use and disclosure of such Personal Data, how Enerpac Tool Group’s obligations under the DPF are enforced, and how Data Subjects can contact Enerpac Tool Group with any inquiries or complaints.

Specifically, Enerpac Tool Group collects human resources data for use in the context of the employment relationship, consisting of typical employee data such as name, address, phone number, email address, and financial and bank information for payment of wages. Enerpac Tool Group also collects sales, marketing and customer data for use in the sales of products or providing of services, consisting of typical customer or prospect data such as name, address, phone number, email address and for a customer, financial and bank information for payment for goods or services. The data would only be disclosed to third parties who assist with IT services and have contractual obligations to protect data and comply with GDPR and other privacy regulations or third party providers of typical employee benefit services such as health care providers or financial services providers.

2. Choice
If Personal Data covered by this DPF Policy is to be used for a new purpose that is materially different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party, Enerpac Tool Group will provide Data Subjects with an opportunity to choose whether to have their Personal Data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to: privacy@enerpac.com .

If Sensitive Personal Data covered by this DPF Policy is to be used for a new purpose that is different from that for which the Personal Data was originally collected or subsequently authorized, or is to be disclosed to a third party, Enerpac Tool Group will obtain the Data Subject’s explicit consent prior to such use or disclosure.

3. Accountability for Onward Transfer
In the event we transfer Personal Data covered by this DPF Policy to a third party acting as a controller, we will do so consistent with any notice provided to Data Subjects and any consent they have given, and only if the third party has given us contractual assurances that it will (i) process the Personal Data for limited and specified purposes consistent with any consent provided by the Data Subjects, (ii) provide at least the same level of protection as is required by the DPF Principles and notify us if it makes a determination that it cannot do so; and (iii) cease processing of the Personal Data or take other reasonable and appropriate steps to remediate if it makes such a determination. If Enerpac Tool Group has knowledge that a third party acting as a controller is processing Personal Data covered by this DPF Policy in a way that is contrary to the DPF Principles, Enerpac Tool Group will take reasonable steps to prevent or stop such processing.

With respect to our agents, we will transfer only the Personal Data covered by this DPF Policy needed for an agent to deliver to Enerpac Tool Group the requested product or service. Furthermore, we will (i) permit the agent to process such Personal Data only for limited and specified purposes; (ii) require the agent to provide at least the same level of privacy protection as is required by the DPF Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Data transferred in a manner consistent with Enerpac Tool Group’s obligations under the DPF Principles; and (iv) require the agent to notify Enerpac Tool Group if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles. Upon receiving notice from an agent that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, we will take reasonable and appropriate steps to stop and remediate unauthorized processing.

Enerpac Tool Group remains liable under the DPF Principles if an agent processes Personal Data covered by this DPF Policy in a manner inconsistent with the Principles, except where Enerpac Tool Group is not responsible for the event giving rise to the damage.
Enerpac Tool Group is also required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

4. Security
Enerpac Tool Group takes reasonable and appropriate measures to protect Personal Data covered by this DPF Policy from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

5. Data Integrity and Purpose Limitation
Enerpac Tool Group limits the collection of Personal Data covered by this DPF Policy to information that is relevant for the purposes of processing. Enerpac Tool Group does not process such Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the Data Subject.

Enerpac Tool Group takes reasonable steps to ensure that such Personal Data is reliable for its intended use, accurate, complete, and current. Enerpac Tool Group takes reasonable and appropriate measures to comply with the requirement under the DPF to retain Personal Data in identifiable form only for as long as it serves a purpose of processing, which includes Enerpac Tool Group’s obligations to comply with professional standards, Enerpac Tool Group’s business purposes and unless a longer retention period is permitted by law, and it adheres to the DPF Principles for as long as it retains such Personal Data.

6. Access
Data Subjects whose Personal Data is covered by this DPF Policy have the right to access such Personal Data and to correct, amend, or delete such Personal Data if it is inaccurate or has been processed in violation of the DPF Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the Data Subject’s privacy, or where the rights of persons other than the Data Subject would be violated). Requests for access, correction, amendment, or deletion should be sent to: privacy@enerpac.com.

7. Recourse, Enforcement, and Liability
Enerpac Tool Group’s participation in the EU-U.S. DPF is subject to investigation and enforcement by the Federal Trade Commission. Enerpac Tool Group is also willing to cooperate with relevant EU data protection authorities regarding this Policy.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, Enerpac Tool Group commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF in the context of the employment relationship.

EU and UK individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF should first contact Enerpac Tool Group at:

Enerpac Tool Group
N86 W12500 Westbrook Crossing
Menomonee Falls, Wisconsin 53201-3241
Attention: Data Privacy Officer
00 1 262 293 1600
Privacy@enerpac.com

Enerpac Tool Group has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, International Centre for Dispute Resolution-American Arbitration Association (“ICDR-AAA”). If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit
https://go.adr.org/dpf_irm.html for more information or to file a complaint. The services of ICDR-AAA are provided at no cost to you.

Under certain conditions detailed in the DPF, Data Subjects may be able to invoke binding arbitration. For more information visit DPF Binding Arbitration Information.

Enerpac Tool Group agrees to periodically review and verify its compliance with the DPF Principles, and to remedy any issues arising out of failure to comply with the DPF Principles. Enerpac Tool Group acknowledges that its failure to provide an annual self-certification to the U.S. Department of Commerce will remove it from the Department’s list of DPF participants.

Changes to this DPF Policy
This DPF Policy may be amended from time to time consistent with the requirements of the DPF. Appropriate notice regarding such amendments will be given.