Policies

Your privacy is very important to us. This Privacy Policy discloses how KKT, Inc. dba: Lockwood Manufacturing Company collects, protects, uses and shares personal information gathered about you, in conformance with applicable law. All personal information is collected in a fair and non-intrusive manner, with your voluntary consent. Personal information is not accessible to anyone outside the specific function for which it is collected. We recognize the need for appropriate protection and management of personal information that you provide to us. This Privacy Policy will assist you to understand what type of information we may collect, how that information may be used, and whom the information may be shared.

In an effort to comply with the law, and our commitment to protect your personal information, we provide the following, which discloses our policies.

What type of information do we collect?

Personal information is any information concerning the personal or material circumstances of an identified or identifiable individual. An identifiable person is one who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, culture or social identity. Personal Information shall include but is not limited to: identifying information such as name, home address, home telephone number, e-mail address, Social Security number and employment-related information such as may be found on resumes, applications, background verification information, or an employment references. We will not collect sensitive Personal Information, except to comply with Affirmative Action data requirements. Sensitive Personal Information can include but is not limited to: information pertaining to gender, disabilities and veteran status.

Cookies – Internet Users

In addition to Personal Information, we use data collection devises such as “cookies” on certain web pages. Cookies are pieces of information a website sends to an individual’s hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to turn off all cookies, use the options on your browser to assist you. The “Help” option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you will not have access to many features available on our website.

Children and Data Collection

We care about the safety of children. We will not knowingly allow anyone under 13 to provide us any personally identifying information. Children under 13 years of age are required to obtain the express permission of a parent or guardian before submitting any Personal Information about themselves (such as their names, Email addresses, and phone numbers) over the internet.

Our use of Your Information

We use your Personal Information to facilitate the services you request. We have tailored our Privacy Policy to adequately inform you of the use of your Personal Information.

Collection and Use of Employee Personal Information.

KKT, Inc. dba: Lockwood Manufacturing Company collects Personal Information from its employees and applicants (human resource data) in connection with administration of its Human Resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs. It is our policy to keep all past and present employee information from disclosure to third parties. There are certain business related exceptions and they are:

1. To comply with county, state or federal agency requests:

2. Inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verification is acceptable. (See below).

3. Third parties with which KKT, Inc. dba: Lockwood Manufacturing Company has contractual agreements to assist in administration of company sponsored benefits. Verifications of Employment, state agencies and financial institutions that contact KKT, Inc. dba: Lockwood Manufacturing Company requesting information on a former or current employee’s work history and salary. All such requests of this type shall be completed on a confidential basis by the Human Resources Department or Payroll Department. For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee’s signed authorization to release information form. The form will be returned directly to the requesting party and filed as part of the Human Resources or Payroll Department’s confidential records.

Medical Information

KKT, Inc. dba: Lockwood Manufacturing Company is compliant with federal HIPPA regulations and only utilizes information related to the company sponsored healthcare plan on a “need to know” basis for administration of the healthcare plan.

Disclosure, Storage, Retention and Accuracy of Personal Information

Except as described in the Privacy Policy, KKT, Inc. dba: Lockwood Manufacturing Company will not disclose Personal Information to a third party, unless such disclosure is requested, there is consent to such disclosure, or disclosure is required by law. KKT, Inc. dba: Lockwood Manufacturing Company insures that Personal Information is safeguarded against loss, access, use, modification, disclosure, or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information. KKT, Inc. dba: Lockwood Manufacturing Company will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws and your consent to such purpose(s) remains valid after termination of our relationship with you. We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

Changes to our Privacy Policy

This Privacy Policy may be amended at any time, without prior notification.

Contact Information

You may contact the Office Manager to access, correct or delete your Personal information. If necessary, the Office Manager will contact another employee to assist in completing your requested task. If you have any concerns or questions or complaints please contact the Office Manager at (734)425-5330 ext. 27; by fax at; (734) 425-0661; by email at: denise@lockwoodusa.com; or by mail at: KKT, Inc., dba: Lockwood Manufacturing Company Attn: Human Resources, 31251 Industrial Road, Livonia, MI 48150.

We will address your concerns and attempt to resolve any problems.

Safe Harbor Compliance

KKT, Inc. dba: Lockwood Manufacturing Company is in compliance with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union member countries and Switzerland. KKT, Inc. dba: Lockwood Manufacturing Company has certified

that it adheres to the Safe Harbor Privacy Principes. The principles of Safe Harbor compliance are:

Notice – Individuals must be informed that their data is being collected and about how it will be used;
Choice – Individuals must have the ability to opt out of the collection and forward transfer of the data to third parties;
Onward Transfer – Transfers of data to third parties may only occur to other organizations that follow adequate data protection principles;
Security – Reasonable efforts must be made to prevent loss of collected information;
Data Integrity – Data must be relevant and reliable for the purpose for which it was collected;
Access – Individuals must be able to access information held about them, and correct or delete it if it is inaccurate;
Enforcement – There must be effective means of enforcing these rules.

Additional information about Safe Harbor principles and certification process can be found at www.export.gov/safeharbor.

Revised: 05/12/2012