Privacy Policy

Last Updated On 1-Nov-2023
Effective Date 1-Nov-2023

Available in Other Languages

1. Data controllers and Kito Crosby’s commitment to your privacy

Kito Crosby Limited is committed to respecting and protecting your privacy and personal information. This Privacy Policy provides details on how We collect, use, process, share, and safeguard the personal information We receive from you and about you when you use our websites, content, or mobile applications (collectively the “Sites“), as well as purchase our products, interact with us, visit our premises, or otherwise use our services (together with the Sites, the “Services“). This Privacy Policy generally applies to all Services operated by or on behalf of Kito Crosby Limited, and our subsidiaries and business units worldwide (collectively, “Kito Crosby“). Specifically with respect to the website kitocrosby.com (hereinafter the “Website“), the subsidiary (part of the Kito Crosby group; hereinafter the “Kito Crosby Subsidiary“) and Kito Crosby Limited (collectively, “We“) are the data controllers of the processing of personal data related to the Website.

We encourage you to review this Privacy Policy. By using or visiting the Services, you acknowledge the terms of this Privacy Policy and agree to our Terms and Conditions of Use (the “Terms“). Use of our Services is voluntary. If you do not agree to the Privacy Policy and the Terms, you must immediately cease such use.

2. The personal data we collect

Personal Data is any information that enables us to identify you and that is related to an identified or identifiable natural person. We may collect Personal Data from and about you from a variety of sources. We strive to only collect Personal Data that is adequate, relevant, and limited to achieve the purpose(s) for which it was collected, and to keep all Personal Data accurate, complete, and reliable for its intended purpose and for no longer than that. We may collect the following categories and types of Personal Data depending on the type of interaction you have with us:

Identifiers including first and last name, mailing address, email address, telephone number, IP address and position in a company;

Financial information including credit card number and other financial information required to purchase our products and services (in many occasions, this data can be related to legal persons and will not qualify as Personal Data. However, there could be some exceptions related to when a natural person employed by the company is the one performing certain transactions on behalf of the company);

Metadata, involving Internet or other electronic network activity information including the unique device identifier of your mobile device, mobile network information, the model and serial number of your mobile device, information regarding your access to and use of an App, the Site pages you visit and the time of your visits, your operating system, browser type, and the domain name of your internet service provider. This type of metadata is usually processed by the different computer elements in order to function;

Professional assessment criteria including job function, language skills, work permission, employment status, academic records, qualifications, skills, professional expertise, , evaluations, feedback from peers and managers and other information that may be useful in assessing whether a current employee or applicant is suitable for a particular position within Kito Crosby group.

Location Information such as geolocation information from your mobile device;

Audio, Electronic, Visual or Similar Information such as photos, videos, service call recordings, or facility camera footage; and

Inferences drawn from Personal Data such as information about your preferences or likelihood to purchase our products or services.

3. How we collect the data

Information you share with us.

We may collect Personal Data when you provide it to us directly, such as through our business interactions with you (i.e. your first and last name, email address, telephone number, sector in which you operate); when you visit one of our locations (i.e. camera footage); when you contact us with questions, requests, feedback, or complaints (i.e. email address, postal code); or when you interact with us on our website, our online customer portals, or through social media (i.e. preferences or likelihood to purchase our products or services).

For example, if you visit our website to register a product or engage in certain activities such as ordering a product or service, requesting a demo, or entering a contest, We may ask that you provide us your name, contact information, and product identifying information.

Information collected through a reseller.

We may collect your Personal Data (i.e. first name and last name, email address, postal code) when you purchase one of our products online or through a distributor. For example, dealers and referral sources provide Kito Crosby with Personal Data of third-party customers and other individuals.

Information collected automatically.

We may collect Personal Data automatically when you visit our website through logging and analytics tools, cookies, and from your use of and access to our customer online portals (i.e. unique device identifier of your device, your operating system, browser). We use cookies and other analytics tools to personalize and enhance your experience online, to collect data about your visit to our website, to help diagnose problems with our servers, to administer and improve our website and our online services, to evaluate the effectiveness of our marketing and advertising campaigns, to permit analytics providers to gather information about your visit, and to gather broad demographic information about our users. We use the data collected through cookies and other analytical tools to store information; provide custom, personalized content (i.e. your selected preferred language); monitor the traffic, use, and effectiveness of our websites and applications (i.e. number of times you visit our website during a certain period of time); diagnose or fix problems (i.e. detected glitches or multimedia content which cannot be reproduced); and improve user access (i.e. login credentials, shopping cart items and site preferences). Additional information about cookies and other analytics tools can be found in our Cookies Policy in the footer of the Website.

Information obtained from third parties.

We may collect Personal Data from third-party sources, including our service providers, such as Google Analytics, through your interactions with us on social media, through industry, marketing, or trade associations, and through public agencies or credit bureaus.

You have choices about certain information We collect. When you are asked to provide your Personal Data, you may decline to do so. However, if you choose not to share Personal Data that is necessary for us to provide any aspect of our services, you may not be able to use those services.

When We collect Personal Data from you indirectly through third parties, We will endeavor to inform you as soon as practicable, but at the latest within one month or in our first communication with you, of the identity of the third-party information source and what We intend to do with the Personal Data. Moreover, to the extent that you provide us Personal Data related to another individual, you warrant that you have the right to provide such Personal Data, and you will be fully responsible for any liability arising from any such use of Personal Data, including indemnifying Kito Crosby from any such liability.

Finally, We may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and this is not Personal Data. To the extent this information is stored or associated with your Personal Data, We will process it as Personal Data; otherwise, it is not subject to this Privacy Policy. Except as otherwise stated in this Privacy Policy, your IP address, cookies and other technologies (as more particularly described below) are generally used by Kito Crosby on an anonymous basis (i.e. without directly referring to you by name), among other things to (1) help diagnose problems with Kito Crosby’s server, administer the Services, measure the use of the Services, improve the content of the Services; (2) to identify visitors’ domain names, the type of web browsers used, the pages viewed, the websites from which a visitor found this Services, the websites to which a visitor went after leaving the Services; the search terms and search engines used to find this Services; and (3) to gather other web analytics information relating to visitors’ use and navigation of the Services. We will comply with applicable laws regarding our use and processing of your data.

4. Cookies and other technologies

We use cookies on this Website as explained in our Cookie Policy, as well as in our Cookie Banner and Cookie Settings.

5. How we use personal data and legal basis

We may process your Personal Data for, or based on, one or more of the following legal bases:

Your Consent: when you opt-in to receive our materials, including marketing and promotional materials, We may process your Personal Data to send messages to you about us and the products and services We offer. You may withdraw your consent at any time.

Performance of a Contract: We may use your Personal Data to enter, or perform under, the agreement between us and you or the business with which you are associated.

Legitimate Interests: We may use your Personal Data for our legitimate interests, including improving our services; providing information about our products and/or services; preventing and detecting fraud; ensuring network and information security; and for administrative and legal compliance purposes.

Compliance with legal obligations and protections of individuals. We may use your Personal Data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harm.

Kito Crosby may use your information for business purposes in accordance with the law for activities, including, without limitation:

to provide services requested and administer product registration, warranties, and rebates

The legal basis used for this purpose is Compliance with Legal Obligations and Protection of Individuals.

The categories of Personal Data processed are: Identifiers, Financial Information and Metadata.

to support our internal activities, such as marketing, product and service development, and dissemination of investor information

The legal basis used for this purpose could be (i) Your Consent (if you have expressly provided it to us), (ii) Compliance with Legal Obligations and Protection of Individuals (if the purpose is more oriented towards product and service development), or (iii) Legitimate Interest (for specific projects related to quality improvement as well as specific aspects related to marketing).

The categories of Personal Data processed are: Identifiers, Financial Information, Metadata, Location Information and Inferences drawn from Personal Data.

to process a job application that you may submit to us, manage your login details on our careers platforms and use recruitment tools that allow us to assess applicants’ suitability for specific roles

The legal basis used for this purpose could be (i) Performance of a Contract (in order to take steps at the request of the data subject prior to entering into a contract) and (ii) Compliance with Legal Obligations and Protection of Individuals.

The categories of Personal Data processed are: Identifiers and Professional assessment criteria.

to enable Kito Crosby to comply with laws, regulations, or legal requests, including to enforce this Privacy Policy

The legal basis used for this purpose is Compliance with Legal Obligations and Protection of Individuals.

The categories of Personal Data processed are: Identifiers, Financial Information, Metadata, Professional assessment criteria, Location Information, Audio, Electronic, Visual or Similar Information and Inferences drawn from Personal Data.

to support certain internal processes to ensure protection of property and interests, including fraud detection, internal auditing, supporting internal and external investigations, and conducting security assessments

The legal basis used for this purpose could be (i) Compliance with Legal Obligations and Protection of Individuals and (ii) Legitimate Interests (in relation to defending the legal position of Kito Crosby).

to enable you to contact Kito Crosby, and for us to respond to you; and

The legal basis used for this purpose could be (i) Your Consent (which you expressly grant by completing and submitting a form to us) and (ii) Legitimate Interests (related to Kito Crosby’s interest in responding to the people who had contacted it through various channels).

The categories of Personal Data processed are: Metadata and Inferences drawn from Personal Data.

to operate and improve equipment, services, websites, mobile applications, and support

The legal basis used for this purpose could be (i) Your Consent, (ii) Legitimate Interests (related to the Kito Crosby’s interest in improving the quality of our services or our communications, or in connection with Kito Crosby’s interest in help end users, even if they do not have a direct contractual relationship with Kito Crosby group) and (iii) Compliance with Legal Obligations and Protection of Individuals.

The categories of Personal Data processed are: Identifiers, Financial Information, Metadata, Location Information, Audio, Electronic, Visual or Similar Information and Inferences drawn from Personal Data.

6. Disclosure of your personal data

Kito Crosby may share information about you for the purposes listed above and in accordance with applicable law with:

Kito Crosby’s affiliates and business units worldwide. As of the effective date of this Privacy Policy, if you are located in a qualifying jurisdiction, your personal information might be transferred to the affiliates included in Section 16 (List of affiliates) below.

Distributors, dealers, or other business partners in connection with the Services as permitted by law, and where required by law, subject to your consent. These parties will process information needed to perform their functions and in accordance with our agreements with them. Kito Crosby’s affiliates, distributors, dealers, or other business partners may use this information for marketing and solicitation purposes.

Our outsourced service providers, vendors, and consultants, such as merchant services providers, IT consultants, incident response and business continuity vendors.

Credit card authorization service providers and the credit card-issuing bank to confirm and settle payment for products or services purchased on the Services and to facilitate returns or refunds.

Our marketing, communications, and advertising partners.

public where you have included information in our blogs, forums, and discussion groups.

legal entities, on a temporary or permanent basis, in connection with a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all our business otherwise changes.

the relevant parties (1) in response to a subpoena, search warrant, court order, or other legal process or request, or as may otherwise be required by applicable law or regulation; (2) to protect and defend Kito Crosby’s rights or property or those of its affiliates, distributors, dealers, business partners, or others; (3) to enforce or apply the Terms or any applicable end user license agreement; or (4) as Kito Crosby, in its sole discretion, believes is appropriate under exigent circumstances in response to a perceived threat to the personal safety or property of any person or organization; and

any other third party where you have provided your consent if such consent is required.

Kito Crosby may share aggregated anonymous information relating to visitors to and users of the Services with affiliated or unaffiliated third parties.

Kito Crosby does not sell your Personal Data to any third parties, and We have not done so in the prior 12 months.

7. Countries where we process your personal data

The Sites are currently hosted on servers located within the United States, but the locations of Kito Crosby’s servers may change from time-to-time. Your Personal Data may be stored on servers located within the United States, or in another country. In addition, Kito Crosby may transfer your Personal Data to affiliates, distributors, dealers, business partners, or others located in the United States or other countries in accordance with, and for the purposes as described in, this Privacy Policy.

In these circumstances, Kito Crosby will ensure that your Personal Data is adequately protected, as required by law.

In these cases the transfers are based on standard contractual clauses approved by the Commission of the European Union and, where applicable, the UK Information Commissioner’s Office. For more information on the above safeguards or the fact that they have been provided, you may contact us to the address indicated at the end of this policy

8. Your rights and choices regarding your data

Depending on applicable data protection and privacy laws, you may be entitled to a variety of legal rights regarding the collection and processing of your Personal Data.

Individual rights vary depending on the laws of the jurisdiction applicable to you, but may include:

The right to know whether, and for what purposes and from what source, We collect and/or process Personal Data.
The right to access, modify, or correct Personal Data.
The right to know with whom We have shared your Personal Data, for what purpose, and what Personal Data has been shared.
Where processing of Personal Data about you is based on consent, the right to withdraw your consent to such processing.

The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you.

The right to request restriction of processing of your Personal Data or object to processing of your Personal Data carried out pursuant to (i) our legitimate interest or (ii) performance of a task in the public interest (including, but not limited to, processing for direct marketing purposes).
In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Data about you in a machine-readable format.

In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain Personal Data we process about you.
The right to opt out of the sale of your Personal Data. We note that We have not and do not sell your Personal Data.
The right to appeal against the decisions we make regarding the processing of your Personal Data; you may exercise this right be replying to the correspondence you receive from us, or by contacting us at the address listed at the end of this Privacy Policy.
The right to lodge a complaint with a regulator, including relevant supervisory authorities, located in the jurisdiction of your residence, place of work, or where an alleged violation of law occurred.

You may exercise these rights, to the extent they apply to you, by contacting us at the addresses listed below. Note, however, that we may request certain reasonable additional information (that may include Personal Data) to help us authenticate your identity, your request, and/or to clarify or understand the scope of such requests.

You also have choices about how we communicate with you and how we process certain Personal Data about you. You may opt-out of receiving marketing or other communications from us at any time by following the opt-out link or unsubscribe information in correspondence you receive from us. If you opt-out of receiving email from us or otherwise modify the nature or frequency of promotional communications, it may take up to ten (10) business days for us to process your request and you may continue to receive promotional communications from us during that period. You will continue to receive administrative messages regarding our services, or transactions you have entered with us, even after opting out of promotional communications.

Note our websites do not take any action in response to “do not track” signals that may be transmitted by some web browsers. Third-party advertising networks are not permitted to collect information about our users.

9. Retention of your personal data

Kito Crosby keeps your Personal Data if Kito Crosby needs it for the purposes for which it was originally collected (or to which you have subsequently consented), for other legitimate purposes (such as regulatory compliance), or as otherwise required or permitted by applicable law or for as long as We need to keep evidence of our actions because We may still have a legal liability in respect of our relationship with you (for example, because our hypothetical liabilities in connection with the processing of your personal data have not yet expired). In some jurisdictions it may be that during this last period of time in which We process your data We do so by blocking (preventing anyone from having access to such personal data unless they can prove that it is in connection with potential legal liabilities or at the request of competent authorities).

You may contact us at the address below for further details about our data retention periods in relation to your Personal Data.

10. Kito Crosby’s relationship to other sites or mobile applications that can be accessed through the services

The Services may contain links to other unaffiliated websites or mobile applications. Additionally, other websites or mobile applications may contain links to the Services. When you access these third-party sites and services, you leave our Site, and we are not responsible for and do not control the content, security, or privacy practices employed by these websites and services. This Privacy Policy does not apply to such other websites or mobile applications; please refer to the privacy notices for such third parties for information about how they collect, use, and process your Personal Data. Kito Crosby does not review or monitor the websites linked to the Services and is not responsible for the contents, terms of use, or privacy policies related to any other websites or mobile applications. Where the Services contain a link to another website or mobile application owned and/or operated by Kito Crosby, such website or mobile application use may be subject to different and additional terms of use and privacy policies. You should make sure you are comfortable with the information that a third-party social networking service may make available to us by carefully reviewing the service’s privacy notice and terms and conditions and by modifying your privacy settings directly on that service.

11. Collection of personal data from minors

Kito Crosby’s Services are not directed at or intended for children under the age of 18. If you are under the age of 18, please do not use or submit any Personal Data to us. By using our services, you represent that you are 18 years of age or older. If you have reason to believe that we may have accidentally received Personal Data from an individual under age 18, please contact us immediately at 1-800-233-3010.

12. Kito Crosby’s commitment to security of your personal data

Kito Crosby has implemented appropriate physical, managerial, and technical measures to protect the security of data and information and to ensure a level of security of Personal Data appropriate to the risks of a breach. Unless applicable law provides otherwise, Kito Crosby does not guarantee against any loss, misuse, unauthorized disclosure, alteration, or destruction of data, including Personal Data. While Kito Crosby strives to protect your data, Kito Crosby cannot always guarantee the security of any information you transmit to or from the Services, and you provide such information at your own risk. You acknowledge that: (1) there are security and privacy limitations in computer systems and on the Internet which are beyond Kito Crosby’s control; and (2) any such information and data, including Personal Data, may be viewed, or tampered with by a third party while such information or data is being used, transmitted, processed, or stored.

13. Non-discrimination and non-retaliation

We respect your rights, and we will never discriminate or retaliate against you because of your exercising any right outlined in this Privacy Policy or afforded to you under applicable law.

14. Changes to Privacy Policy

Kito Crosby may change its Privacy Policy from time to time. This Privacy Policy was made effective on the date indicated above. Notwithstanding the fact that we will notify you of such changes if We are required to do so by applicable law, Kito Crosby encourages you to review this Privacy Policy regularly in your use of the Services and especially before you provide any information. Your continued interaction with us or your continued use of our Services will amount to your acknowledgement of the amended Privacy Policy.

15. How to contact us

To exercise any applicable rights, or if you have questions, please contact us at the address below:

By email: paul.johnston@kitocrosby.com

By mail: Kito Crosby

Attn: Paul Johnston, Chief Privacy Officer

410 West End Boulevard

Manheim, PA 17545

16. List of affiliates

The affiliates as of the effective date of this Privacy Policy which would receive the personal information as set out in Section 6 are:

Kito Crosby Limited
Gunnebo Industries Pty Ltd.
Crosby Europe NV
Gunnebo Industries Produtos Para Movimentacao de Cargas Ltda
Crosby Canada Inc.
Airpes China, Co. Ltd.
Crosby Europe France S.a.r.l.
Forge France SAS
Parsons Chaine Europe SAS
Gunnebo Industries GmbH
Rhombus Rollen GmbH & Co
Rhombus Rollen Verwaltungsgesellschaft mbH
Schmiedestuck-Vertrieb Feuerstein GmbH
Gunnebo Industries Ltd
Lifting Holdings BidCo, Inc
Inter Products BV
Gunnebo Anja Industrier AS
Gunnebo Industries Holding AS
Gunnebo Industries Sp.z.o.o
Crosby APAC Pte. Ltd.
Airpes Sistemas Integrales de Manutencion y Pesaje, S.L.
Griffon Acquisition AB
Gunnebo Industrier Group AB
Gunnebo Industrier Holding AB
Gunnebo Industrier AB
Blokcorp Ltd
Crosby Europe (UK) Limited
Crosby UK Acquisition Limited
Straightpoint UK Limited
The Crosby Group UK Limited (fka Gunnebo Industries Ltd)
Acco Material Handling Solutions, Inc.
Amdura LLC
Crosby US Acquisition Corp.
FKI Hardware, Inc.
FKI Industries, Inc.
Babcock Industries Inc.
Crosby Investment Inc.
GJC Investments Inc.
Gunnebo Industries Inc.
The Crosby Group LLC
The Crosby Group Manufacturing LLC
Anchor Nominees Pty Ltd
KITO Australia Pty Ltd
PWB Anchor Limited
Kito do Brasil Comercio de Talhas e Guindastes Ltda
Kito Canada Inc
Kito Hoists & Cranes (Shanghai) Co. Ltd.
Jiangyin Kito Crane Co., Ltd.
Erikkila OY
Kiinteisto OY Alamos
Kito Europe GmbH
Kito India Private Limited
PT Kito Indonesia
Kito Chain Italia SRL
SHT S.r.l.
Kito Corporation
Security Chain Company Japan
Van Leusden B.V.
Van Leusden Nederland B.V.
KitoHoists & Crane Asia Pte Ltd
Kito Korea Co., Ltd.
Kito Taiwan Co., Ltd.
KitoHoist Thai Co., Ltd.
Siam Kito Co., Ltd
Sukit Business Co. Ltd.
Harrington Hoists, Inc.
Kito Americas, Inc.
Peerless Chain Company, Inc
Peerless Industrial Group, Inc

17. Jurisdiction-specific information

We provide below additional information about the privacy, collection, and use of personal information in certain jurisdictions.

17.1 Australia

Personal Information We Collect. Personal Information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

Your Rights and Choices regarding your Personal Data. You have the right to make a complaint at any time to the appropriate data protection supervisory authority (in Australia this is the Office of the Australian Information Commissioner (OAIC) – https://www.oaic.gov.au/about-the-OAIC/contact-us). We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.

Controller and Processor of Personal Information. Details of the personal information handling business operator for personal information provided to or collected by Kito Corporation is as follows:

Name: Kito Crosby Australia

Address: 441 Grimshaw Street, Bundoora, VIC 3083

Email: vicsales@kitopwb.com.au

17.2 Brazil

Your rights under LGPD

Brazilian users are entitled the following rights under Brazilian Data Protection Law (Law No. 13,709/2018 or LGPD):

Right to Confirmation of data processing activities performed by us in connection with your personal data;

Right to Access to the data We have available about you;

Right to Rectify data that We have available about you;

Right to Anonymization, Restriction to the processing or Elimination of personal data, to the extent that you believe that such data is no longer necessary or is excessive for the purpose for which We informed, or, additionally, when you believe that the processing activities conducted by us in connection with such data are not in accordance with data protection laws;

Right to Erase personal data that We process based on consent, except in those cases where the law provides for exceptions to this right;

Right to Information on third parties with whom your personal data has been shared;

Right to Information on the possibility of not giving consent and the consequences thereof;

Right to Review decisions made based solely on automated data processing;

Right to Portability of personal data;

Right to Withdraw consent at any time, where consent has been provided;

Right to Object to the processing, where the processing is not based on consent, and the processing is unlawful;

Right to Bring a claim before the Data Protection Authority (ANPD) against Kito Crosby (https://www.gov.br/anpd/pt-br).

17.3 Canada

If you live in Canada, the following Section 5 will replace Section 5 in the Privacy Policy:

5. How We Use Personal Data and Legal bases

We process your Personal Data based on your consent, and for one or more of the following reasons:

Marketing and Promotional Materials: When you opt-in to receive our materials, including marketing and promotional materials, We may process your Personal Data to send messages to you about us and the products and services We offer. You may withdraw your consent at any time.

Performance of a Contract: We may use your Personal Data to enter, or perform under, the agreement between us and you or the business with which you are associated.

Legitimate Interests: We may use your Personal Data for our legitimate interests, including improving our services; providing information about our products and/or services; preventing and detecting fraud; ensuring network and information security; and for administrative and legal compliance purposes.

Compliance with Legal Obligations and Protection of Individuals: We may use your Personal Data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harm.

Kito Crosby may use your information for business purposes in accordance with the law for activities, including, without limitation:

to provide services requested and administer product registration, warranties, and rebates

The legal basis used for this purpose is Your Consent and could also be Compliance with Legal Obligations and Protection of Individuals.

The categories of Personal Data processed are: Identifiers, Financial Information and Metadata.

to support our internal activities, such as marketing, product and service development, and dissemination of investor information

The legal basis used for this purpose is Your Consent and could also be (if you have expressly provided it to us), and (i) Compliance with Legal Obligations and Protection of Individuals (if the purpose is more oriented towards product and service development), or (ii) Legitimate Interest (for specific projects related to quality improvement as well as specific aspects related to marketing).

The categories of Personal Data processed are: Identifiers, Financial Information, Metadata, Location Information and Inferences drawn from Personal Data.

to process a job application that you may submit to us, manage your login details on our careers platforms and use recruitment tools that allow us to assess applicants’ suitability for specific roles

The legal basis used for this purpose is Your Consent and could also be (i) Performance of a Contract (in order to take steps at the request of the data subject prior to entering into a contract) and (ii) Compliance with Legal Obligations and Protection of Individuals.

The categories of Personal Data processed are: Identifiers and Professional assessment criteria.

to enable Kito Crosby to comply with laws, regulations, or legal requests, including to enforce this Privacy Policy

The legal basis used for this purpose is Your Consent and could also be Compliance with Legal Obligations and Protection of Individuals.

to support certain internal processes to ensure protection of property and interests, including fraud detection, internal auditing, supporting internal and external investigations, and conducting security assessments

The legal basis used for this purpose is your Consent and could also be (i) Compliance with Legal Obligations and Protection of Individuals and (ii) Legitimate Interests (in relation to defending the legal position of Kito Crosby).

to enable you to contact Kito Crosby, and for us to respond to you; and

The legal basis used for this purpose is Your Consent (which you expressly grant by completing and submitting a form to us) and could also be Legitimate Interests (related to Kito Crosby’s interest in responding to the people who had contacted it through various channels).

The categories of Personal Data processed are: Metadata and Inferences drawn from Personal Data.

to operate and improve equipment, services, websites, mobile applications, and support

The legal basis used for this purpose is Your Consent and could also be (i) Legitimate Interests (related to the Kito Crosby’s interest in improving the quality of our services or our communications, or in connection with Kito Crosby’s interest in help end users, even if they do not have a direct contractual relationship with Kito Crosby group) or (ii) Compliance with Legal Obligations and Protection of Individuals.

17.4 China

“China” as used in this Privacy Policy refers to the People’s Republic of China, and, only for the purpose of this Privacy Policy, does not include Hong Kong, Macau and Taiwan.

Among the personal data we collect as specified in Section 2 (The Personal Data We Collect), the following may be considered as “sensitive personal data” as regulated by the Personal Information Protection Law of the People’s Republic of China: metadata, such as information regarding your access to and use of an App, the Site pages your visit and the time of your visits and the domain name of your internet service provider; location information, such as geolocation information from your mobile device; and any other sensitive personal data that you may provide to us. We collect and process sensitive personal data only for specified, explicit and reasonable purposes and to the extent directly relevant to the purposes of processing. We will process your sensitive personal data in a way that has the least impact on your personal rights and interests.

By using our Website or providing your personal data to us, you will be deemed as having accepted and fully agreed to be bound by, and you consent to our processing of your personal data in accordance with this privacy policy, including the processing of your sensitive personal data. You acknowledge, understand and agree that our processing of your personal data primarily takes place outside of China and your personal data will be stored outside of China.

In addition, you may contact us as specified in Section 5 (How to Contact Us) to obtain information regarding the third parties who act in the capacity of independent data controllers and with whom we share your personal data. By using our Website or providing your personal data to us, you will be deemed as having consented to our sharing of your personal data to the relevant recipients specified in Section 6 (Disclosure of your Personal Data).

17.5 India

Without limiting and in addition to the terms of this Policy, the following terms may be applicable to the processing of Personal Data if you are located in India.

Diclosure of your Personal Data

Kito Crosby requires all third-parties, by written contract, to implement appropriate security measures to protect your Personal Data consistent with any data security obligations applicable to us.

How to contact us

To exercise any applicable rights, or if you have questions or complaints about our collection, use or disclosure of Personal Data, or if you believe that we have not complied with this Privacy Policy, please contact us at: paul.johnston@kitocrosby.com

17.6 Indonesia

“Compliance with Legal Obligations and Protection of Individuals” in Section 5 in the Privacy Policy is replaced with the following:

Compliance with Legal Obligations and Protection of Individuals: We may use your Personal Data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harm as long as it is required under relevant laws and regulations.

You are entitled to the right to deem that certain personal information that you provided to us is to be treated as confidential. If this right is exercised, and certain personal information is deemed confidential, we will not share your personal data with any third parties. However, limiting the list of personal information that we can share to third parties may impact your ability to receive services and communications from us. We will elaborate the impact when you opt for exercising this right.

This Privacy Policy may be translated into any local languages of Indonesia in order to meet relevant laws and regulatory requirements. Both versions of the English language version and the local language version are equally authentic. In case of any discrepancy between the two versions, the relevant part of the local version will be deemed to be automatically amended in order to conform with the relevant part of the English version.

17.7 Japan

Controller of Personal Information. Details of the personal data handling business operator for personal information provided to or collected by Kito Corporation is as follows:

Name: Kito Crosby

Address: 2000, Tsuijiarai, Showa-cho, Nakakoma-gun, Yamanashi 409-3853, Japan

Representative: Yoshio Kito, President

Joint Use of Personal Information. We will share your personal data which we collect as set out in Section 2 above with our affiliates. The affiliates will use your personal data for the same purposes set out in Section 5 above for their own. Kito Corporation is responsible for management of personal data jointly used among affiliates.

17.8 Republic of Korea

Controller of Personal Information. The details of the personal data processor of the personal information provided to or collected by Kito Korea Co., Ltd. (“Kito Korea”) are as follows:

Name: Kito Korea Co., Ltd.

Address: [15, Pangyo-ro 228beon-gil, Bundang-gu, Seongnam-si, Gyeonggi-do,], Republic of Korea

Representative: Yoshio Kito, President

Personal Data Protection Officer. Kito Korea’s personal data protection officer in charge of the personal data processing is:

You may opt not to give consent to the cross-border transfer of your personal data. In such case, your use of our Services for which cross-border transfer of your personal data is necessary may be limited.

Process and method of destroying personal data. Your personal data will be destroyed without delay once Kito Crosby no longer needs your personal data, including but not limited to where the personal data retention period has expired or the purpose the personal data was collected has been achieved. Your personal data will be destroyed.

How to respond to a personal data breach.

In case your personal data has been breached, you may contact the Personal Information Dispute Mediation Committee or the Personal Information Breach Report Center, and also report to the contact information provided below and ask for consultation.

Name of the department and person in charge: paul.johnston@kitocrosby.com

17.9 Thailand

Definitions. The terms “personal data,” “data subject,” and “data controller” shall have the meaning as defined in the Personal Data Protection Act, B.E. 2562 (2019) and its sub-regulations (“PDPA“).

Data Subject Rights. In accordance with the PDPA, you have the following rights to:

request a copy of your personal data that We collect, use, and/or disclose about you. Where necessary, We may require you to prove or authenticate yourselves prior to our compliance with your request.

You may have the right to object to certain collection, use, and disclosure of your personal data, on grounds relating to your particular situation.

You may have the right to restrict the use of your personal data in certain circumstances.

Controller of personal information. Details of the data controller in Thailand for Personal Data provided to or collected by Kito Corporation is as follows:

Contact details: paul.johnston@kitocrosby.com

Cross-border data transfers. We may share your personal data which We collect with our affiliates or third parties who are in other country for the purpose set out in this Privacy Policy. Some countries may have a higher or lower level of data protection standards than in Thailand. In this case, We well ensure an adequate degree of protection is afforded to the transferred Personal Data, or that the transfer is otherwise permitted in accordance with the PDPA, when it is necessary to transfer any Personal Data to a third country with a level of data protection standards lower than those of Thailand. The Company may, for example, obtain contractual assurances from any third party given access to the transferred Personal Data that such data will be protected by data protection standards which are equivalent to those required in Thailand.

17.10 USA

California

This California addendum (“California Addendum”) explains how Kito Crosby collects and processes identified or reasonably identifiable information about California residents who use our Services.

California personal information. Depending on your online and offline interactions with us, Kito Crosby may collect and process the following categories of personal information (“California Personal Information”):

Identifiers, including first and last name, mailing address, email address, and telephone number;
Personal information as described in subdivision (e) of Section 1798.80, including credit card number and other financial information required to purchase our products and services;
Commercial information, including purchasing history;
Professional or employment-related information, including relevant experience and organization information;
Educational information, including professional qualifications;
Internet or other electronic network activity information, including your IP Address, the unique device identifier of your mobile device, mobile network information, the model and serial number of your mobile device, information regarding your access to and use of an App, the Site pages you visit and the time of your visits, your operating system, browser type, and the domain name of your internet service provider. This type of metadata is usually processed by the different computer elements in order to function;
Audio, electronic, visual or similar information, such as photos, videos, service call recordings, or facility camera footage;
Geolocation data, such as geolocation information from your mobile device
Inferences such as information about your preferences or likelihood to purchase our products or services; and
Other, including warranty assistance information as information about you that is linked to the California Personal Information above, such as inquiry and communication information when you contact us.

Certain California Personal Information that Kito Crosby collects about you may be considered Sensitive Personal Information within the meaning of California Privacy Law, including: government identifiers that we collect for compliance and related legal purposes, credit card information that we collect to process your purchases, and precise geolocation information to use our Services. We only use and disclose such data to the extent necessary for compliance with Federal and other laws, and as otherwise permitted by California Privacy Law.

Sources. Kito Crosby generally sources the categories of California Personal Information identified above directly from you (for instance, when you provide information as part of a business transaction or otherwise), through a reseller, and from third-parties. We may also collect certain information automatically. See Section 3 above for more detail.

Purposes of use. Kito Crosby uses California Personal Information for:

Business purposes, including:
- to provide services requested and administer product registration, warranties, and rebates;
- to support our internal activities, such as marketing, product and service development, and dissemination of investor information;
- to process a job application that you may submit to us, manage your login details on our careers platforms and use recruitment tools that allow us to assess applicants’ suitability for specific roles;
- to enable Kito Crosby to comply with laws, regulations, or legal requests, including to enforce this Privacy Policy;
- to support certain internal processes to ensure protection of property and interests, including fraud detection, internal auditing, supporting internal and external investigations, and conducting security assessments;
- to enable you to contact Kito Crosby, and for us to respond to you; and
- to operate and improve equipment, services, websites, mobile applications, and support.
Commercial purposes, including:
- Advertising, marketing, and public relations (including direct marketing);
- Market research and analysis;
- To display personalized advertising when you visit our Sites or a third party website;
- To contact you with special offers and other information we believe will be of interest to you;
- To invite you to participate in surveys and provide feedback to us;
- To better understand your needs and interests; and
- To improve our marketing and promotional efforts.

Disclosure of California personal information.

We may disclose the categories of California Personal Information described above for the business purposes described above to:
- Kito Crosby’s affiliates and business united worldwide;
- Distributors, dealers, or other business partners in connection with the Services as permitted by law. These parties will process information needed to perform their functions and in accordance with our agreements with them. Kito Crosby’s affiliates, distributors, dealers, or other business partners may use this information for marketing and solicitation purposes;
- Our outsourced service providers, vendors, and consultants, such as merchant services providers, IT consultants, incident response and business continuity vendors;
- Credit card authorization service providers and the credit card-issuing bank to confirm and settle payment for products or services purchased on the Services and to facilitate returns or refunds;
- Our marketing, communications, and advertising partners;
- The public where you have included information in our blogs, forums, and discussion groups;
- Legal entities, on a temporary or permanent basis, in connection with a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction, or if the ownership of all or substantially all our business otherwise changes; and
- The relevant parties (1) in response to a subpoena, search warrant, court order, or other legal process or request, or as may otherwise be required by applicable law or regulation; (2) to protect and defend Kito Crosby’s rights or property or those of its affiliates, distributors, dealers, business partners, or others; (3) to enforce or apply the Terms or any applicable end user license agreement; or (4) as Kito Crosby, in its sole discretion, believes is appropriate under exigent circumstances in response to a perceived threat to the personal safety or property of any person or organization.
We may disclose Identifiers, Internet or other electronic network activity information, and Geolocation data for the commercial purposes described above to:
- Business partners including social media and ad networks.

Kito Crosby does not sell your California Personal Information to any third parties, and We have not done so in the prior 12 months.

Retention of California personal information.

See Section 9, Retention of Your Personal Data, above.

Your rights. Subject to certain exceptions detailed in California Privacy Law, as a California resident, you have the right to request: (i) deletion of your California Personal Information; (ii) correction of inaccurate California Personal Information; (iii) the right to know/ access the categories of California Personal Information that we collect about you, including the specific pieces of California Personal Information; (iv) the categories of California Personal Information disclosed for a business purpose; and (v) information about the categories of California Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the California Personal Information was shared. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.

Exercising your rights. If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the California Personal Information collected or shared with third parties, please see the “Contact us” section. When submitting your request, please include the specific nature of your request, referencing “Your California Privacy Rights,” as well as your first and last name, email address, and zip code or mailing address. Kito Crosby may apply any exceptions or other conditions available under law when responding to correction, deletion, or other requests. Kito Crosby will generally fulfil requests for access, correction, and deletion within 45 days of receiving a valid request. Kito Crosby may extend the response time by another 45 days by notifying the individual of the time extension.

Do not sell or share my information. In addition to the above, California residents have the right to opt-out of the selling or sharing of their California Personal Information, as such terms are defined under California Privacy Law. This includes the right to opt-out of analytical/performance, functional, and targeting cookies. To exercise this right, click the Change Cookie Preferences link in the footer of the website. In addition, we have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control (“GPC”) within the browser. Due to technical limitations, the GPC signal is only honored within the particular browser. Beyond GPC, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our sites.

Authorized Agents. To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

CONTACT US

See Section 15, How to Contact Us, above.

Other US States

Exercising Your Rights

When you submit a request to exercise your rights as noted above in Section 8, note that not all of the rights listed may be conferred upon by your state’s privacy regulation.

Right to appeal

Residents of certain US States have the right to appeal a Kito Crosby decision in respect of your privacy rights. To appeal a decision, send an email to paul.johnston@kitocrosby.com with details of your original request and appeal.