Privacy Policy for Markem-Imaje Customers | Updated October 2023
1. INTRODUCTION
- processed in a lawful, fair and transparent manner about the data subject ('lawfulness, fairness and transparency);
- collected for specified, explicit and legitimate purposes and will not be further processed in a manner incompatible with those purposes;
- adequate, relevant and limited to what is necessary concerning the purposes for which they are processed ("data minimization");
- accurate and, if necessary, up to date; all reasonable steps shall be taken to ensure that personal data which are inaccurate regarding the purposes for which they are processed are erased or rectified without delay ("accuracy");
- kept in such a way as to permit the identification of data subjects for no longer than is necessary for the processing of personal data;
- processed in such a way as to ensure adequate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by applying appropriate technical or organizational measures ('integrity and confidentiality').
This Privacy Notice (the "Privacy Notice") is intended to provide our customers and their employees ("Customer", "You") with information about how your personal data will be collected, used, shared and
protected within the processes that the Company will deploy, which are described in more detail in the following sections (the "Processes").
You can find the latest version of this Privacy Notice at https://www.markem-imaje.com/privacy.
2. WHO IS THE "CONTROLLER" OF SUCH PERSONAL DATA?
Any type of request can be sent to us in the following languages, German, Spanish, French, English Italian, or Portuguese.
3. WHAT DATA IS COLLECTED OR PROCESSED?
The Company processes your personal data to effectively manage the business relationship with you or your company, as described below in Section 4.
We do not collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or the processing of genetic data, biometric data to uniquely identify a person or data relating to health or sex life and sexual orientation, or any other type of data protected under the Personal Data Regulation in force.
The personal data processed by Markem-Imaje, come directly from users who have given their prior consent to its collection and processing in writing and/or in a reliable manner, by any existing means and that has created a link with our Company.
The table below sets out what personal data we collect, the purpose of the collection and what lawful basis we rely upon when processing that personal data.
| Purpose of processing your personal data | Category of personal data collected | Lawful basis |
| Delivering our Services and record keeping to our customers or those interested in our services | Personal identifiers (name, contact details, email address, telephone number) | Our legitimate interest is in delivering our Services to you, responding to communications from you in connection with our Services and retaining internal records to evidence (potential) customer interactions. |
Direct Marketing such as administering promotions and offers which you register for plus serving online ads. | Personal identifiers (name, contact details, email address) | We will do this with your consent where required by applicable law. Where you are an existing customer, we will rely on our legitimate interest to grow our business where the law permits. |
| Commercial information: records of products or Services purchased, obtained, or considered, other purchasing or consuming histories or tendencies | Our legitimate interest is in understanding and improving our business and Services. | |
| Site and Services improvements, network and system security | Internet or other electronic activity information: information we obtain through your interaction with our Site, including time and date of your visit, IP address, pages visited, and length of visit. | Our legitimate interest is in improving the products and Services offered through the Site. To conduct an internal analysis to understand how many unique visitors visit the Site and to measure the areas of the Site that are of most interest to visitors. Our legitimate interest is to protect the security of our systems from adverse events. |
| Legal and regulatory obligations we have to comply with including requests from public and government authorities | Personal identifiers (name, contact details, IP address, email address, telephone number) | Compliance with a legal obligation - Where we are required to collect and disclose your personal data because we are subject to a legal or regulatory obligation. |
| To protect our or a third party's rights and property – defending legal claims, taking legal action | Personal identifiers (name, contact details, email address, telephone number) | Our (or a third party's) legitimate interests to protect rights and property. |
Sensitive data recognized by current legislation will not be processed by Markem-Imaje.
No Sale of Personal Data: We do not sell your personal data.
4. FOR WHAT PURPOSES DO WE PROCESS THE DATA?
Your personal data may also be processed in connection with any legal process or claims, for the Company to establish, exercise or defend its legal rights, or to comply with legal obligations, including, but not limited to, following a request from a competent administrative or judicial authority or in any circumstance in which such processing is requested by applicable laws.
The processing of your personal data will always be based on legitimate grounds.
The Company will process the personal data described above for the following purpose(s):
- fulfill our contractual obligations to customers and administer contracts and agreements;
- verify identity, which may include natural persons, where a contractual relationship is proposed or exists, to assess financial capability and other business risks to our business;
- maintain an up-to-date and centralized database of customers;
- process quotes, orders, billing, delivery and payment of our products and services;
- offer maintenance services and contracts;
- provision of support and maintenance services;
- provide training;
- carrying out marketing and communication campaigns related to our products and services (sending emails and telephone prospecting) and sending invitations to events;
- provide and manage e-commerce and sales order automation solutions;
- organization of meetings and monitoring of the commercial relationship;
- correspond with lawyers, legal advisors, advisors and financial partners;
- conduct customer surveys and case studies;
- produce trade statistics;
- manage cookies.
Legitimate interests: The processing described is necessary to administer and facilitate our business relationship and for the legitimate interest of the Company.
More information about this analysis can be provided upon request, via our email privacy@markem-imaje.com.
Performance of a contract: The processing described is necessary to enter into or for the execution of your commercial agreements and contracts and to administer their management.
5. WHO HAS ACCESS TO SUCH PERSONAL DATA?
The Company establishes a limit on access to personal data held by us only those members of the Company, who need them for a legitimate business purpose.
Personal data is shared on a "need to know" basis. Only those people who need the data to fulfill a business objective should have access to their personal data, and only for as long as they need it to fulfill the purpose.
Individual recipients are not authorized to share their personal data with other employees or third parties unless such sharing is authorized and complies with all applicable Company policies.
For the processes, we anticipate the following categories of recipients will have access to your personal data, for the purposes indicated below:
Sales and Marketing teams: The Company's Sales and Marketing teams, each in its field of responsibility, will access and process some of your staff data for the purposes described in Section 4 and for marketing campaigns and event invitation management,
development of business statistics and for the management of business relationships.
Financial Equipment: The Company's Finance team will access some of its staff data and process it for the purposes described in Section 5, to assess the financial condition and other business risks of our business and to process billing and payment.
IT Teams: The IT teams of Dover Corporation (Parent Company) and the IT teams of the Company, as well as any IT subcontractor acting on behalf of Dover Corporation, or on behalf of the Company, may access some of the data of its personnel to provide and
support IT services.
Compliance Equipment: Dover Corporation and the Company's Compliance teams may access some of your personal data to conduct third-party due diligence and to comply with export control regulations.
Legal Team: The legal teams of Dover Corporation and the Company may access some of your personal data to carry out the corresponding legal proceedings under the contract, negotiations or legal proceedings that may be established based on the existing
contractual relationship.
Some of the recipients mentioned above may be located outside the EU, EEA, Switzerland or the UK and are likely to be in many countries around the world. As described in Section 6 below, all such transfers to internal recipients will comply with all applicable laws and regulations, following the requirements of the applicable General Data Protection Regulation.
The Company may from time to time engage third-party vendors to assist in processing personal data. The Company will transmit to any of these providers its obligations under applicable data privacy law, require the provider to secure the data, and provide
such additional notice as required by law. We will not sell, distribute or transfer your personal data to third parties unless we have your prior consent that will be informed.
6. WHERE IS THE DATA TRANSFERRED AND FOR WHAT LEGAL REASONS?
Your personal data may be transferred outside the EU or the UK to countries which are not subject to an adequacy decision issued by the European Commission at the UK Secretary of Stata (as applicable) or the Swiss Federal Council, for the purposes listed above under the European Commission's Standard Contractual Clauses (SCC) (europa.eu), or other legally binding and permissible agreement at the time of the Transfer.
In such a case, Markem Imaje undertakes to put in place all appropriate safeguards to offer a sufficient level of protection to your Personal Data, and in particular to carry out a transfer impact assessment and implement all additional corrective measures necessary to guarantee a level of protection at least equivalent to that conferred by the applicable regulation.
Such transfers will comply with all applicable laws and regulations from time to time. We anticipate that this data may be transferred to various countries around the world.
Relevant additional details may be provided based on transfers of personal data upon request addressed to privacy@markem-imaje.com.
Your personal data may also be processed and subsequently transferred in connection with any legal proceedings or future legal proceedings, for the Company to establish, exercise or defend its legal rights, or to comply with legal obligations, including,
but not limited to, upon a request from a competent administrative or judicial authority or in any circumstances where such processing is requested following applicable laws.
7. DATA SECURITY
We are committed to ensuring the security of your personal data. To prevent unauthorized access or disclosure, we have put in place appropriate technical and organizational measures to safeguard and secure the personal data we process. We employ a set of various IT security tools to safeguard personal data, restrict access to data and have physical and organizational security measures in place to prevent unauthorized or unlawful access to personal data and accidental loss, destruction or damage to personal data. The Company also maintains an inventory of personal data and evaluates the safeguards we have in place for that data to ensure that our security measures are tailored to the sensitivity of the data.
For illustrative purposes, the following specific security measures apply:
- Perimeter protection has been established through firewalls, as well as monthly vulnerability scanning, and intrusion detection and prevention systems to protect against malicious access.
- An encryption mechanism is used when data is transmitted outside the company and Dover group network, as well as on all data at rest on mobile devices.
- Authentication mechanism with a strong password policy and Role-Based Access Control to authorize access to the various resources on which personal data is stored and processed.
- Regular safety awareness training for all employees to increase our defense.
- Information Security Governance, including a security incident management response plan, as well as a Cybersecurity program improvement plan based on NIST's Cybersecurity Framework (CSF), as a guideline for measuring, improving, and monitoring our overall security program.
We have established procedures to deal with any suspected data breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
All our external service providers and other group entities are required to take appropriate security measures to protect your personal data per our policies and the risk involved. We do not allow our third-party service providers to use the provided personal data for their purposes. We only allow them to process their personal data for specific purposes and according to our instructions.
8. INFORMATION ON DATA RETENTION
We will retain your personal data for as long as:
- Let us maintain a commercial relationship with you;
- In the event that Markem Imaje is required to fulfill a legal obligation, personal data is processed for the time necessary to fulfill this obligation and as provided for by law;
- For the time strictly necessary to use the website and to access the services;
- In the context of marketing operations, three (03) years from the last contact;
- Until the withdrawal of consent, in the event that the processing is based on prior consent;
- In accordance with local country regulations.
If you have any questions about our retention policy, please contact us using the details above.
9. RIGHTS OF DATA SUBJECTS
The rights of the interested parties will be by the regulations in force and the jurisdiction in which you reside. However, you can always ask the Company for more information about the people who will be able to see and access the data that identifies you.
At any time, you can request the update of your data, but we also remind you that you must notify any information that directly affects the updating of your personal information, having to communicate it as soon as possible, and thus being able to maintain the quality of the data we process for our commercial relationship.
We remind you of the rights granted to you by the current Regulation, without incidentally mentioning the existing rights under your jurisdiction:
- Right to request access to your personal data.
- Right to request rectification or erasure.
- Right to request the limitation of your treatment.
- Right to object to processing.
- Right to data portability.
- Right to withdraw the consent given at any time.
The Company is committed to ensuring that all data is protected against unlawful use.
If you believe that your data and information have been used in violation of applicable laws, regulations or data protection provisions, please notify the Company and the Company will inform you.
In cases of non-compliance by the Company, at the time of responding or processing your rights, you may file a claim with the Data Protection Control Authority, of your country of origin, by the provisions of the European Union, in the following link you can locate your Control Authority: Our Members | European Data Protection Board (europa.eu). If your home country is Switzerland, your supervisory authority is the Federal Data Protection and Information Commissioner (see Startseite admin.ch). If your home country is the UK, you can complain to the data protection authority of the United Kingdom using their website at https://ico.org.uk.
But remember that before submitting any claim to the Control Authority, you must have previously notified the Company of the possible incident or exercise of Law always by email: privacy@markem-imaje.com.
We remind you that, to process any type of incident or Law, we must verify your identity, requiring your identity document, if necessary, insofar as the exercise of these rights is subject to certain legal conditions and limitations, we may have to reject your request if these conditions are not met or if legal limitations apply.
In addition, the Company has the power to reject unreasonably repetitive requests, require disproportionate technical effort (e.g., developing a new system or fundamentally changing an existing practice), or create a risk to the privacy of others. In any case, we will try to process your request under the legally established deadlines.
There will be no silence on the part of the Company when responding to requests, while if it proceeds or is rejected it will be notified if we have reliable proof of your request.
10. COOKIES
We collect certain information through our use of cookies. For detailed information on the cookies, we use and the purposes for which we use them, please see our Cookie Policy https://www.markem-imaje.com/cookies.
To the extent permitted by applicable law, Markem-Imaje may also use your personal data as we believe to be necessary or appropriate:
- Under applicable law, including laws outside your country of residence;
- To comply with legal process;
- To respond to requests from public and government authorities including public and government authorities outside your country of residence where strictly required, necessary and proportionate;
- To investigate and resolve complaints, grievances or misconduct allegations;
- Health and safety purposes;
- Defending legal claims;
- To enforce our terms and conditions;
- To protect our rights, privacy, safety or property, and/or that of our Affiliates, you or others; and
- To allow us to pursue available remedies or limit the damages that we may sustain.
