Privacy Policy

Policy On the Collection, Use and Disclosure Of Personal Information

Objective & Scope of Policy
Ferraz Shawmut (formerly R-Theta Thermal Solutions). is committed to respecting your privacy and has prepared this document to inform you of our policy and practices concerning the collection, use and disclosure of Personal Information.

Definition of Personal Information
Personal information is information about an identifiable individual or company. Personal information includes information that relates to their personal characteristics (gender, age, income, home address, etc), their health, activities and views as well as business information (a business address, telephone number, e-mail address etc.).

Collection of Personal Information
In the course of providing services to our clients, we collect personal information on occasion. Our primary purpose for collecting personal information is typically related to the following:

• address information for contact purposes
• contact information from clients requesting information about our services
• information posted to our website
• information stored to allow client login access

Personal information is collected directly from the individual or company concerned. Unless permitted by law, no personal information is collected about an individual or company without first obtaining the consent to the collection, use and dissemination of that information.

Use and Disclosure of Personal Information
Ferraz Shawmut use of personal information is limited to the purpose of effectively providing professional and competent services to our clients. R-Theta Thermal Solutions, Inc. will only disclose personal information if necessary in the performance of these services, or at the express direction of the client.

Ferraz Shawmut may disclose personal information of clients to organizations that perform services on its behalf (i.e. Shipping/Carrier Companies). This will only be done if such organizations agree to use such information solely for the purposes of providing services to Ferraz Shawmut and, with respect to that information, to act in a manner consistent with this Policy.

Ferraz Shawmut does not sell, trade, barter or exchange for consideration any personal information it has obtained.

Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where Ferraz Shawmut is obliged to disclose information without consent. Such circumstances may include:

• Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
• Where Ferraz Shawmut believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
• Where it is necessary to establish or collect monies owing to Ferraz Shawmut;
• Where it is necessary to permit Ferraz Shawmut To pursue available remedies or limit any damages that Ferraz Shawmut may sustain;
• Where the information is public; or
• Where obliged or permitted to disclose information without consent, Ferraz Shawmut will not disclose more information than is required.

Personal information may also be transferred to another company in the event of a change of ownership of all or part of Ferraz Shawmut

Accuracy of Personal Information
Ferraz Shawmut endeavors to ensure that any personal information provided by clients and in its possession is as accurate, current and complete as necessary for the purposes for which Ferraz Shawmut uses that data. Information contained in files that have been closed is not actively updated or maintained.

Retention of Personal Information
Ferraz Shawmut retains personal information as long as we believe it is necessary to fulfill the purpose for which it was collected. In some circumstances, legal, financial or business requirements will dictate the retention period. Wherever appropriate, Ferraz Shawmut will destroy any personal information not actively being used or required for retention.

Safeguarding Personal Information
Ferraz Shawmut Endeavors to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information.

Access to Personal Information
Ferraz Shawmut permits access to and review of personal information held by R-Theta Thermal Solutions, Inc. about an individual or company by the individual or company concerned.

If an individual or company believes any personal information is not correct, they may request an amendment of that information by sending a request to our Privacy Officer.

Ferraz Shawmut reserves the right to decline access to Personal Information where the information requested:

• Would disclose the Personal Information of another individual or of a deceased individual;
• Would disclose business confidential information that may harm Ferraz Shawmut or the competitive position of a third party;
• Is subject to solicitor-client or litigation privilege;
• May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions;
• Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information; or
• Does not exist, is not held, or cannot be found by R-Theta Thermal Solutions, Inc.

Where information will not or cannot be disclosed, the individual or company making the request will be provided with the reasons for non-disclosure.

Where information will be disclosed, R-Theta Thermal Solutions, Inc. will endeavor to provide the information within a reasonable time and no later than 30 days following the request.

To guard against fraudulent requests for access R-Theta Thermal Solutions, Inc., will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.

Notification of Changes to the Privacy Statement
If Ferraz Shawmut decides to change this privacy statement; those changes will be posted on the Ferraz Shawmut website home page www.r-theta.com so that the client is always aware of what information is collected, how it is used, and under which circumstances, if any, it is disclosed.

Questions
Questions about this privacy policy or requests to view personal information should be directed to our Privacy Officer: