Enerpac Tool Group Privacy Notice

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the EU’s General Data Protection Regulation (“GDPR”), including but not limited to, employees and customers of Enerpac Tool Group.

2. Responsibilities

2.1 The Data Privacy Officer is responsible for ensuring that this notice is made available to data subjects prior to Enerpac Tool Group collecting/processing their personal data.

2.2 All employees of Enerpac Tool Group who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

Enerpac Tool Group is a pure play tool company with operations in more than 25 countries. The Enerpac Tool Group businesses are market leaders in industrial tools and services, and are global leaders in high pressure hydraulic tools, controlled force products and solutions for precise positioning of heavy loads. Our contact information is:

• Enerpac Tool Group Corp.
N86 W12500 Westbrook Crossing
Menomonee Falls, WI 53051

• 00 1 262 293 1600 (tel)

Our Data Privacy Officer (for all legal entities in all locations) can be contacted directly here:

• Enerpac Tool Group, Corp.
Attn: Data Privacy Officer
N86 W12500 Westbrook Crossing
Menomonee Falls, WI 53051


3.2 Personal Data

Under the GDPR, personal data is defined as any information relating to an identified or identifiable natural person (i.e., “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal data will only be processed by Enerpac Tool Group in a reasonable, lawful and fair manner. This means that Enerpac Tool Group will process personal data in compliance with applicable data protection laws and/or other laws and regulations. Examples of common types of personal data include name, address, social security number, salary details and financial information, CV’s, employee records and reviews, and references regarding employees.

The GDPR distinguishes between ordinary personal data such as name, address and telephone number and sensitive personal data including information relating to health, sexual orientation, racial or ethnic origin, political opinions, religious beliefs, and trade union membership. Under the law the processing of sensitive personal data is subject to additional and stricter conditions.

Enerpac Tool Group will not process personal information without a lawful basis to do so. Our legal basis for collecting and using your customer information will depend on the information concerned and the specific context in which we collect it. In general, Enerpac Tool Group will process customer information on the legal bases of consent, contract (if you have entered into an agreement with us and such processing is a necessary part thereof), or legal obligation. If we ask you to provide user information to comply with a legal requirement or so we can perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of this user information is mandatory or not (as well as of the possible consequences if you do not provide this user information).

Employee/applicant/candidate personal data is processed by Enerpac Tool Group on the basis of consent and/or contract, for the purposes of employment management and compliance with legal requirements. Individuals should note that Enerpac Tool Group will only process sensitive personal data in limited circumstances.

Where required by law, the explicit consent of the individuals to such processing will be obtained. Enerpac Tool Group will take appropriate security measures to safeguard sensitive personal data and to ensure its confidentiality
In order to operate effectively and to meet its legal requirements, Enerpac Tool Group needs to process personal data for employment-related purposes. Where it does so, personal data will be collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with these purposes. Processing of certain data will for some activities continue after employees have left the service of Enerpac Tool Group.

Examples of the main ways in which Enerpac Tool Group processes personal data in an employment context may include the following:

1. Recruiting and staffing;
2. Administration of salaries and expenses, pension, sickness benefit or other payments and contributions due under the contract of employment;
3. Monitoring absence or sickness under an absence control policy;
4. Administration of incentive compensation programs;
5. Training and development, including performance appraisals;
6. Management planning;
7. Appraisal, promotion and salary progression reviews;
8. Negotiations with trade unions or other employee representatives;
9. Administration of Enerpac Tool Group policies;
10. Compliance with any legal requirement to provide information about employees including regarding tax payments or employee membership lists to unions;
11. Administration of any applicable disciplinary and grievance procedures;
12. Compilation of employee lists and contact information for both internal and external use;
13. Production of employee ID cards;
14. Monitoring the use of Company resources;
15. In relation to the provision of company services and other services;
16. To contact emergency contacts or emergency services in the event of an emergency, for example, illness or serious injury to an employee.

Employees and external candidates/applicants are asked to provide personal data at the point of application and throughout their employment for the purposes mentioned above. Enerpac Tool Group will inform employees of any material changes in the way in which employee personal data is used.

Employee data maintained by Enerpac Tool Group will be used for the purposes, as mentioned above, of supporting company operations and providing employee benefits and compensation. Enerpac Tool Group HR and Payroll processes include tasks and procedures to keep personal data accurate, complete and current.

3.3 Consent
Enerpac Tool Group will not process your personal data without a lawful basis to do so. Our legal basis for collecting and using your personal information will depend on whether you are an employee or a customer. In general, Enerpac Tool Group will process your personal information on the legal bases of consent, contract or legal obligation. If we ask you to provide information to comply with a legal requirement or so we can perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of this information is mandatory or not (as well as of the possible consequences if you do not provide this information).

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for Enerpac Tool Group to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by following the process set forth in the Withdrawal of Consent Procedure, GDPR DOC 2.7A.

3.4 Disclosure

Enerpac Tool Group is comprised of a group of companies worldwide. Certain employee data contained on the centralized database will be accessible to other members of the Enerpac Tool Group companies, such as the United States and/or other countries, for the purpose of customer or employee management and as outlined in this Policy. Additionally, there are situations when personal data relating to employees is transmitted to third parties (EU or non-EU based) to provide HR related services for Enerpac Tool Group, such as payroll services, compensation, expenses, employee engagement surveys, cultural and/or employee engagement assessments, healthcare services and other employee benefits and services/information required by law.

In addition, Enerpac Tool Group, like many businesses, sometimes hires other companies (EU and non-EU based) to perform certain business-related functions. Examples include mailing information, maintaining databases and processing payments. When Enerpac Tool Group retains a non-affiliated company to perform a function of this nature, such third party will be required to take security measures to appropriately protect the data.

Personal data may also be proportionately disclosed by Enerpac Tool Group to other third parties as required by law, for compliance with legal requirements or to defend a legal claim, in an emergency to protect the vital interests of an employee, in cases of business requirements (such as the sale of a business unit), or where the consent of the employee has been obtained.

Personal Data may be transferred to or processed in locations outside of the European Economic Area (EEA), some of which have not been determined by the European Commission to have an adequate level of data protection. In that case, for personal data subject to European data protection laws, we take measures designed to provide the level of data protection required in the EU, including ensuring transfers are governed by the requirements of the Standard Contractual Clauses adopted by the European Commission, or another adequate transfer mechanism. Enerpac Tool Group entities have entered into intragroup transfer agreements based on the Standard Contractual Clauses which allows for the processing and transfer of personal data. A copy of these agreements can be requested by request to Privacy@enerpac.com.
Enerpac Tool Group has the authority to change or terminate this policy in whole or in part at any time, without prior notice to or the consent of any employee, unless otherwise described by local and/or European legislation and requirements.

3.5 Retention period
Enerpac Tool Group will process personal data and will store the personal data for as described in Enerpac Tool Group’s Retention Period Procedure, GDPR DOC 2.3.

3.6 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organization.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Enerpac Tool Group refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.7 Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Enerpac Tool Group (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Enerpac Tool Group’s Data Privacy Officer.

3.8 Privacy statement
Read more about how and why we use your data in the Enerpac Tool Group privacy statement found at www.enerpactoolgroup.com.

4. Document Owner and Approval

The Data Privacy Officer or designee is the owner of this document and is responsible for ensuring that this policy document is reviewed in line with the requirements of the GDPR.

A current version of this document is available to all employees on the Enerpac Tool Group corporate intranet (“the HUB”) and through Human Resources. It does not contain confidential information and can be released to relevant external parties. This document is also available by request to the Company at privacy@enerpac.com.