Last updated: 11 November 2024

1 Introduction

Kalmar Corporation (hereinafter “we” or “Kalmar”) collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). This Supplemental Privacy Policy for California Residents (“Supplemental Privacy Policy”) supplements and is expressly made part of the information contained in Privacy Statement - Customers, Partners and Vendors and Privacy Statement - Website and Marketing. If you are a California resident, you have additional rights and choices under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Acts of 2020 (CPRA), from hereon referred to as “CCPA”.

The purpose of this Supplemental Privacy Policy is to provide consumers with timely notice, at or before the point of collection, about the categories of Personal Information to be collected from them, the purposes for which the Personal Information is collected or used, and whether that Personal Information is sold or shared, so that consumers have a tool to exercise meaningful control over the use of their Personal Information.

2 Categories of Personal Information

Kalmar has collected and disclosed the following categories of Personal Information of consumers for business and commercial purposes during the preceding twelve (12) months:

We may also collect, use, and share aggregated data, such as statistical or demographic data, for any purpose (“Aggregated Data”). Aggregated Data could be derived from your Personal Information, but Aggregated Data is not considered Personal Information, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing our websites and services. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this Supplemental Privacy Policy.

3 How we collect your Personal Information

We may have obtained the Personal Information either directly or indirectly from you (for example through your use of our website, interactions with marketing, events, online forums and social networks, newsletters and stock exchange release subscriptions), through your employer company or the company to which you are otherwise related to, or through publicly available sources such as social media channels. We may also collect your personal data from public authorities, Kalmar affiliated companies and other third-party relations, depending on the type of the services provided. Examples of third-party sources include:

• Registers held by governmental agencies;
• Financial sanction lists; and
• Registers held by credit-rating agencies and other commercial information providers providing information on, e.g., beneficial owners and politically exposed persons.

4 Purposes

To support your relationship with Kalmar, or your use of our products and services, we may have collected and disclosed Personal Information within the past twelve (12) months for the following types of business and commercial purposes:

1. To provide services to our customers and ensure effective delivery of our services;
2. To manage our customer, vendor and partner relationships;
3. To execute the legal obligation to prevent, detect and investigate bribery, corruption, money laundering and financing of terrorism and to bring money laundering, terrorist financing and the crime by which the property or criminal benefit that is the subject of money laundering or terrorist financing has been obtained, under investigation (“KYC/KYP process”);
4. To execute obligations related to sanctions;
5. To comply with other applicable legal or regulatory requirements and internal policies, documentation and requirements;
6. To handle inquiries, complaints and claims from third parties;
7. To handle inspections and inquiries of supervisory authorities and for the purposes of external audits;
8. To provide newsletter and stock exchange release subscriptions;
9. To operate and improve our websites;
10. To tailor the content of our website to provide you with a more personalised experience and information about Kalmar products and services that might be of interest to our customers;
11. To manage and respond to requests you submit through our website;
12. To market, generate leads and host corporate events, online forums and social networks;
13. To coordinate marketing activities towards registered persons in our Client Relationship Management system, including sending and tracking invitations for events, social networks, and online forums;
14. As described to you when collecting your Personal Information or as otherwise set forth in the CCPA; and 
15. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you a separate notice.

5 Sharing Personal Information

We may share your Personal Information with a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the rights and obligations under the said contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for the business purpose(s) described above:

Category A: Identifiers.

Category B: California Customer Records Personal Information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

We may disclose your Personal Information for a business purpose to the following categories of third parties:

1. Our clients or their agents for which you have engaged in a business contract;
2. Our service providers and business partners; 
3. Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the provision of our services; and
4. Public authorities, insurance companies and our professional service advisors, such as auditors and legal advisors.

6 Selling Personal Information

Selling your Personal Information under the CCPA means us selling, renting, releasing, disclosing, disseminating, making available, or otherwise communicating orally, in writing, or electronically, your Personal Information to a third party for monetary or other valuable consideration. 

Within the last twelve (12) months, we may have sold information within each of the following categories, with the aforementioned third parties:

Category A: Identifiers.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Note we do not sell sensitive Personal Information.

7 Retention of Personal Information

We retain Personal Information for only as long as that data is necessary for the purposes we have collected it, or if we are required to retain that data for longer periods in order to comply with applicable laws. Please note that the data retention obligations will differ within Kalmar due to differences in local laws. The retention period applied to Personal Information in a specific case will depend on the purpose of processing. As an example, information stored for bookkeeping purposes is stored due to a legal requirement for up to ten years.

Please note that in relation to our newsletter and marketing material, you may ask that we delete Personal Information that we hold about you at any time by clicking on the unsubscribe link in the communication or by sending your request by e-mail to privacy@kalmarglobal.com. 

The retention of cookies is described in the Cookie Policy.

8 Rights Relating to Personal Information

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your rights under the CCPA and explains how to exercise those rights.

Right to Know 

You have the right to request that we disclose certain information to you about our collection, use disclosure, and sale of your Personal Information over the past twelve (12) months. Once we verify your consumer request, we will disclose to you:

1. The categories of Personal Information collected about you;
2. Specific pieces of Personal Information collected about you;
3. The categories of sources from which we have collected Personal Information;
4. Our business purposes for which we collect or sell the Personal Information;
5. The categories of third parties with whom we share the Personal Information; and
6. The categories of information that Kalmar sells or discloses to third parties.

Sensitive Personal Information

Sensitive Personal Information means non-publicly available Personal Information that includes or reveals (A) a consumer’s social security number, driver’s license, state identification card, or passport number; (B) a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; (F) a consumer’s genetic data; (G) a consumer’s biometric information processed for the purpose of uniquely identifying the consumer; (H) Personal Information concerning a consumer’s health, or sex life or sexual orientation.

You can direct us to only use your sensitive Personal Information for limited purposes, such as providing you with the services you requested.

Right to Data Portability 

You have a right to obtain a copy of the specific pieces of Personal Information we collected about you (also called a data portability request). Once we verify your request, we will provide you with a copy of your Personal Information that is responsive to your request.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information we collected from you and retained, subject to certain exceptions. Once we verify your consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Opt-out Preference Signals

Opt-out preference signals or Global Privacy Controls (GPC) provide consumers with a simple and easy-to-use method by which consumers interacting with us online can automatically exercise their rights to opt out of sale/sharing. We will process any opt-out preference signals that meet the following requirements: 

1. A signal that is in a format commonly used and recognized by businesses; and 
2. The technology or mechanism that sends the opt-out preference signal makes clear to the consumer that the use of the signal is meant to have the effect of opting the consumer out of sale and sharing of their Personal Information. For example, such technology or mechanism may be an HTTP header field, JavaScript Object, or most commonly, a browser tool or extension that allows users to send the opt-out signal. 

Exercising the Rights under the CCPA

To exercise the right to know, the right to limit, the right to data portability, and deletion rights described above, please submit a verifiable consumer request to us via the channel(s) described in the Contact Us section below.

Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may designate an authorized agent to make a request on your behalf by registering such person or entity with the California Secretary of State.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
2. Describe your request with sufficient detail to enable us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavour to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to an additional 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. 

However, please note that if you refuse to provide your Personal Information to us or ask us to delete or stop selling your Personal Information, and that Personal Information or sale is necessary for Kalmar to provide you with goods or services, we may not be able to complete that transaction.

Notice of Financial Incentives

We do not offer financial incentives or pricing discounts for providing your Personal Information.

Children’s Information

Our website is not intended for children under 13 years of age. We will not knowingly solicit or collect Personal Information from children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. If we learn that we have received information directly from a child under 13 without his or her parent’s or legal guardian’s consent, we will make commercially reasonable efforts to delete such information.

9 Contact Information

If you have any questions or comments on this Supplementary Privacy Policy, the ways in which we collect and use your Personal Information, or your choices and rights regarding such use, or if you wish to exercise your rights under CCPA, you may contact us by email at privacy@kalmarglobal.com or by phone at +358 20 777 4000.

10 Changes to the Supplementary Privacy Policy

We reserve the right to amend this Supplementary Privacy Policy at our discretion and at any time. The date this Supplementary Privacy Policy was last updated is identified at the top of this page. You are responsible for periodically visiting the Kalmar website and this Supplementary Privacy Policy to check for any changes.