Política de Privacidade


Last Updated: September 23, 2020 


Flexcon Company, Inc., headquartered at 1 Flexcon Industrial Park, Spencer, MA 01562, USA, wants you to know how we collect, use, disclose, transfer and store your personal data that we may obtain from you when you visit our website, or otherwise use our services. This Privacy Policy applies to Flexcon Company, Inc and Flexcon Europe Limited (U.K. and Netherlands branches) and its affiliates. It describes what personal data (including Personal Identifiable Information - PII - as defined in the United States) Flexcon Company, Inc. and its affiliates (together “Flexcon”) collect, how and why we collect it, and how we strive to protect it. “Personal data” is information that can personally identify you. Before submitting personal data through our website (Flexcon.com = “Site”) or any of our services, please review this Privacy Policy carefully. BY USING OR ACCESSING THE SITE OR ANY OF OUR SERVICES, YOU ACKNOWLEDGE THAT YOU ACCEPT AND AGREE TO THE PRACTICES AND POLICIES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT USE OR ACCESS THE SITE OR ANY OF OUR SERVICES. The Site is hosted in the United States of America.   
EU/EEA data subjects: Please note our GDPR Data Protection Notice (“Notice”) below. In case of a conflict between this Global Privacy Policy and the Notice, the Notice shall govern.   
1. How we collect your personal data   
a) Personal data collected on our Site and use of “cookies”   
Flexcon processes personal data through the Site that you voluntarily provide to Flexcon that tells us specifically who you are, such as your name, e-mail address, company name, address, or telephone number or any other personal information you share with Flexcon for the proposes described in this Privacy Policy, such as processing of your order and customer service. Flexcon processes these data sets only in the United States. Flexcon may use your contact information to deliver technical support-related service information, as applicable. We use your IP address to help diagnose problems with our server, and to administer our Site. Your IP address is used to help identify you and to gather broad statistical information. IP addresses are also used to provide an audit trail in the case of attempted illegal use of the Site as well as to guard against spamming. The information collected through the use of analytics may include, for example, your IP address, the website from which you visited us, and the type of device you used. You can opt out from the use of Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add On.    
For each visitor to the Flexcon.com website, our web server automatically recognizes and stores information - such as the visitor’s IP address and domain names that may be personal data. We also use data collection devices such as "cookies." Cookies are small files placed on a visitor's hard drive that assist us in providing products and services to our customers. In addition, a visitor may encounter "cookies" or other similar devices on certain pages of the website that are placed by third parties or when ordering online. We do not control the use of cookies by third parties.  
With most Internet browsers, you can erase the type of cookies we use from your computer hard drive, block our cookies, or receive a warning before our cookie is stored. However, please note that while you may still use the website and the services, your actions in connection with such functions will interfere with the website and the services functioning properly.   
b) Other websites   
Other websites that may be linked to/from the Site may have different policies. These links to other websites do not imply affiliation or endorsement of a linked site. You should review the policies on these other websites to understand their policies and practices. Flexcon does not assume, and expressly disclaims, any liability for third parties that have been provided with information as permitted by this Privacy Policy or who have collected information as permitted by this Privacy Policy.   
c) New product offerings /promotional emails    
We will not send you unrelated promotional e-mails unless you have specifically asked to receive them. If you choose to receive promotional e-mails from Flexcon, we will ask you to provide Flexcon with your e-mail address. If at any time after you subscribe to receive e-mail promotions, you may unsubscribe by replying to Flexcon with the word "unsubscribe" in the subject heading of your e-mail (opt-out).  
d) Customer inquiries   
We also collect customer information from customers who call our customer service with inquiries. This personal data is also stored in the third-party lead management system and in a Survey Software that is hosted by a third party as Flexcon’s service provider but will not be disclosed or otherwise made available to any other party.  
f) Vendors and Customers based in the EEA or U.K.   
We may also collect personal data from vendors and customers with whom we work as part of maintaining these relationships and the services provided or received. This personal data is also stored in a database in U.S. and U.K. It will not be disclosed or otherwise made available to any other party.  
2. Disclosure of your personal data   
a) Sharing with third parties   
We do not sell your personal data to third parties for their marketing purposes without your express consent. However, your personal data may be disclosed by us in the normal course of business of providing goods and services to customers, including but not limited to, third party service providers. We do not grant our advertisers access to your personal data. For EU personal data processed under this Privacy Policy, Flexcon has entered or (for new service providers) will enter into arrangements with these third parties to ensure an adequate level of data protection as defined in the GDPR (EU Regulation 2016/679).  
b) Sharing with employees, service providers, etc.    

To the extent permitted by applicable law, the personal data covered in this Privacy Policy may be shared with certain employees, contractors, other companies providing services to Flexcon and affiliate organizations of Flexcon that have a need to know such information for the purposes set forth in this Privacy Policy. Some of those employees, contractors, service providers and affiliated organizations may be located outside of your home country.  The mentioned personal data may be processed by Flexcon and these third parties for customer support purposes, including responding to requests for customer service, offerings of similar products, and communicating with you regarding your satisfaction with your order.   
In addition, Flexcon and its contractors and service providers may process your personal data to:  

  • customize, analyze, adjust and improve the Site and our services to better meet your needs;  
  • respond to your inquiries;  
  • enforce Flexcon’s agreements with you, for instance, if we believe you have or are violating this Privacy Policy on the Site;   
  • provide you with important administrative information regarding the site and the services, such as changes to this Privacy Policy, or our other related policies, and to, more generally, facilitate communication between Flexcon and you;   
  • prevent fraud and other prohibited or illegal activities; and  
  • protect or defend Flexcon’s rights or property, even without a subpoena, warrant or other court order. All personal data will be processed based in the principles of legality, consent, Information, quality, purpose, loyalty proportionality and responsibility, as set forth in applicable law.  

We will ask for your consent before using your personal data for a purpose other than those that are set out in this Privacy Policy.  
c) Data sharing with law enforcement and regulators, restructuring etc.   
We may disclose any information, including, without limitation, the personal data covered by this Privacy Policy, as we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request (e.g., requests and audits by data protection agencies). Flexcon may also grant access to certain information (including your personal data), subject to confidentiality restrictions, in connection with a sale, merger, liquidation, dissolution or insolvency proceeding involving Flexcon or its assets.  
3) Protection against unauthorized access   
Flexcon takes appropriate measures to safeguard your personal data and to prevent unauthorized access to that information in its internal procedures and technology. However, we do not promise, and you should not expect, that your personal data are always safe against cyber-attacks, involuntary data loss or hacking, as such activities are common. Flexcon has implemented physical, electronic and procedural safeguards to protect your personal data from unauthorized access and use. While Flexcon strives to protect your personal data, no data transmission over the Internet is 100% secure and, consequently, we cannot guarantee the security of any information, nor should you expect that your personal data, searches or other communications with Flexcon will always remain secure. You should also be aware that Flexcon has no control over the security of other sites on the Internet that you might visit or interact with even when a link to any such third-party site appears on our site.  
In the event of a breach of the confidentiality or security of your personal data, Flexcon may notify you directly as necessary so you can take appropriate protective steps. Flexcon may notify you under such circumstances using the e-mail address(es) that we have on record for you.   
4) No Marketing to Children   
This Site is a general audience site and does not target or intend to collect personal data from children. Flexcon is concerned about the privacy and safety of children when they use the Internet. We will never knowingly request or collect personal data online from minors without prior verifiable parental consent. To use the Site or any of service, you must be the age of legal majority in your place of residence. By using the Site or any of our services, you hereby represent that you are at least the age of legal majority in your place of residence or have otherwise provided us with parental consent. All information provided to Flexcon will be treated as if it was provided by an adult. In accordance with the US Children’s Online Privacy Protection Act of 1998 and similar non-US laws and regulations, if we discover that a child under 13 has provided us with personal data, we will remove it from our systems.  
5) Removal /update of your personal data, revocation of consent for data processing  
We are not responsible for removing your personal data from the lists of any third party who has previously been provided your personal data in accordance with this Privacy Policy. If you would like to (A) access, rectify, modify or delete your personal data (including, without limitation, your User Login, email address, contact information, user preferences) or (B) revoke your consent for the processing and treatment of your personal data, you can send an email to privacy@Flexcon.com with clear instructions about the personal data that you would like to have accessed, rectified, modified or deleted. You must promptly update your personal data if it changes or is inaccurate.  
6) Revisions to the Privacy Policy   
We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective 30 days after they are initially posted on the Site.  
7) California residents   
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of their personal data to third parties for their direct marketing purposes in the preceding calendar year. We give these users the ability to tell us not to share their personal data with third parties for their direct marketing purposes. To make such a request, please send us an email to privacy@Flexcon.com. We may need additional information to process your request. We do not sell California customers’ personal information as defined in the CCPA (Section 1798.140(t).  
8) How to contact us   
If you have any suggestions, questions or concerns about this Privacy Policy or if you want to know which personal data we have stored pertaining to you, please contact us at:  
 IT Management  
Flexcon Company, Inc.  
1 Flexcon Industrial Park  
Spencer, MA 01562  
Email: privacy@Flexcon.com 
Flexcon COMPANY, INC. and its European Union (“EU”) and U.K. affiliates (identified below) (hereinafter collectively, “Flexcon”, “we” or “us”) collect and process personal information provided to us from, or that we obtain on behalf of, our suppliers/customers/outside contacts in the course of providing services to them.     
The Flexcon affiliates in the EU and U.K. are located at:  
Flexcon Europe Limited  
Whitworth Road  
Southfield Industrial Estate  
Glenrothes, Fife KY6 2TF  
Scotland - UK  
Flexcon Europe Limited  
Flevolaan 3  
1382 JX Weesp  
P.O. Box 131  
1380 AC WEESP  
The Netherlands  
Email contact for both: privacy@Flexcon.com 
Flexcon is not obliged to have a data protection officer under the GDPR at this time.  
This Data Protection Notice (“Notice”) is provided in accordance with applicable privacy laws including, but not limited to, laws implementing the General Data Protection Regulation 2016/679 (“GDPR”) and its national laws referring to it or implementing it (the “Data Privacy Laws”). It applies only to former, current and prospective suppliers/customers/outside contacts (“third parties”) in the European Economic Area or U.K. whose personal data we process on their behalf or on behalf Flexcon (“EU personal data”).  It covers the EU personal data we receive and describes how Flexcon uses this information to serve the third parties and do business with the third parties.    
Flexcon provides various commercial services to our customers. In this respect, we are likely deemed a data controller under applicable Data Privacy Laws with respect to the personal data we obtain from third parties about their personnel and other individuals with whom we work. To the extent that Flexcon is deemed a data controller under applicable Data Privacy Laws, this Notice fulfils our obligation to provide information to the third parties whose personal data we process in this capacity.  
We include in this Notice a summary of rights regarding the personal data of third parties that we process in our capacity as a data controller in the course of our services to our customers and other third parties. In all of these cases, Flexcon’s Global Privacy Policy, as amended, shall apply. Please read it carefully.  
Personal data    
The EU personal data Flexcon processes primarily include contact details for the third parties and their employees and their other personnel, along with any other data relating to such individuals in which they are identified or from which they are identifiable. Only to the extent provided to us by a third party or its employees or other personnel, this includes each individual’s name and contact information, and information about where the individual works.  
Flexcon collects various types of personal data from different sources, including from:   

  • directly from the third parties or our EU/U.K. affiliates;   
  • public sources, such as the internet sites; and  
  • from any vendor engaged by us or by the third parties to provide services on our customer’s behalf.  

Personal data from job applicants in the EU and U.K. are processed in the U.K. according to the applicable employee data protection policy.  
What we do with this personal data   
The personal data Flexcon collects  are processed  and to provide its commercial services to its customers, notably to facilitate our provision of such services, to respond to queries, and for other professional dealings with third parties (legitimate interest pursuant to Art. 6 (1) (f) GDPR). Where and to the extent required by a court order or a request from a governmental or regulatory authority, Flexcon may also disclose this personal data to the court or governmental or regulatory authority.     
Where personnel employed or engaged by a third party and contacts consent to Flexcon’s using their personal data for marketing purposes we use their data to newsletters, new product introductions or promotions, notices of product changes or discontinuations, any legal updates and to invite them to events hosted or sponsored by Flexcon. Individuals can unsubscribe at any time from these marketing communications at any time after initially providing consent as described in the Global Privacy Policy.   
Flexcon will not use this EU personal data for any additional purposes, other than disclosed in this Notice, without the data subject’s express consent to do so, unless we have another lawful ground on which to use this information under the Data Privacy Laws.  Any such consent can be withdrawn at any time by sending an email to privacy@flexcon.com or contacting us in writing. Flexcon is not using EU personal data for automated decision-making, including profiling.   
We are also permitted to process this personal data to comply with our legal and regulatory obligations and/or our contractual obligations to the third parties to provide the services to them and our own legitimate interests.   
Some of this personal data is processed by us outside Europe, including in the United States, and is held on secured servers. Flexcon’s EU and U.K. affiliates take steps to safeguard the privacy and security of all categories of personal data as required under the Data Privacy Laws. Flexcon uses the EU Controller-to-Controller Standard Contractual Clauses that the European Commission has approved and can be obtained through the contacts mentioned in this Notice. Flexcon shares the personal data for the purposes mentioned in this Notice only to the extent that this is necessary to provide the services to our customers and other third parties. Our security measures to protect the personal data are described below in this Notice. We are aware of the recent judgment of the European Court of Justice 311-18 (Schrems II) of July 16, 2020 and are in the process of adjusting our existing data transfer tools. Please contact us if you wish further details.  
We do not allow any third parties to have access to this personal data, except as required or permitted by applicable laws or in accordance with the Global Privacy Policy. We may disclose this personal data to our subcontractors, agents, legal advisers, auditors and other relevant business advisers. Such recipients may be located in the United States. We require that our subcontractors, agents, legal advisers, auditors and other relevant business advisers agree in writing to comply with the privacy and security standards described in this Notice and Data Privacy Laws.   
There may be instances when we disclose this personal data to other parties to:   

  •  Comply with applicable law or respond to compulsory legal processes (such as a search warrant or court order) or in response to a request for information from a regulator or governmental authority, or in the course of actual or anticipated litigation or otherwise for legal purposes; and/or  
  • Protect the rights, property or safety of Flexcon, or any of our respective affiliates, business partners, or other third parties, or otherwise in the legitimate business interests of Flexcon and/or our affiliates and in accordance with Data Privacy Laws.  

We may share EU personal data with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Flexcon's business to that business entity. We will require that such recipients undertake to protect the EU personal data as required by the Data Privacy Laws.  
How Flexcon protects personal data     
 We are regularly audited for adherence to the ISO 9001 standard and are currently certified.  
We backup data every day to a secure offsite location which is GDPR compliant. Firewalls in our facilities are updated by the company IT department.  Hard drives on PCs and laptops are protected by industry-standard encryption software.    
Flexcon understands that storing personal data in a secure manner is an essential requirement of the Data Privacy Laws and, therefore, employs reasonable physical, technical and administrative safeguards to secure such data against foreseeable risks, including unauthorized use, access, disclosure, destruction, or modification. You also have the right to transfer your personal data to another data controller. (data portability). More specifically, our information security team has developed policies, standards and procedures to support and enforce preventive and detective operational controls to ensure the confidentiality, integrity, and availability of Flexcon’s data.  We use preventive and detective controls such as Log Collection Analysis and Event Correlation, Perimeter Protection, Account Security, Physical Security, User Access, Encryption, Data Loss Prevention, and Vulnerability Management to safeguard the data of third parties.  In addition, Flexcon personnel are required to abide by Flexcon’s code of business conduct and confidentiality and data security policies which are available to them online via the company internal network.  
Although we make good-faith efforts to store the information we receive from and on behalf of the third parties in a secure operating environment that is not available to the public, Flexcon cannot guarantee complete security.  Further, while we work to ensure the integrity and security of our network and systems and data transmission lines, we cannot guarantee that our security measures will prevent third-party "hackers" from illegally obtaining this information.  
How long we keep it   
We retain the personal data for the duration of the business relationship with the third party and, depending on the applicable jurisdiction in which a third party is located, after the end of the engagement, unless the information is needed longer for legal, regulatory, audit, and tax requirements. We will delete or anonymize EU personal data that are no longer needed for these purposes without undue delay.  
Privacy rights under the GDPR 
Data subjects in the EEA or the U.K. have the right to access their personal data and to ensure that it is accurate, and to request that we delete and/or restrict the processing of their personal data in accordance with, and subject to, the Data Privacy Laws. To enforce any of these rights, or for any further privacy-related question or concern you may have, you can contact us by email at privacy@flexcon.com.  If you are not satisfied with our response, you can complain to the data protection authority in your country of residence or in the Flexcon affiliate’s place of residence. The contact of the data protection agency for Flexcon in the EU is Autoriteit Persoonsgegevens, PO Box 93374, 2509 AJ Den Haag, The Netherlands, website https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us