Last Updated: 26^th, August 2026

PLEASE READ THIS PRIVACY POLICY (THE “POLICY”) CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AS WELL AS WHAT CHOICES AND RIGHTS YOU MAY HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SERVICES.

By accessing, visiting, browsing, or using our website or other STW North America Services, registering or submitting your information through our Services (collectively, the “Services”), or otherwise interacting with us, you acknowledge that you have read, understood, and agree with the terms and conditions of this Policy.

THE SERVICES ARE INTENDED FOR USERS LOCATED IN THE UNITED STATES AND ARE NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES. IF YOU ARE ACCESSING THE SERVICES FROM OUTSIDE THE UNITED STATES, YOU DO SO AT YOUR OWN RISK AND ARE RESPONSIBLE FOR COMPLIANCE WITH LOCAL LAW. WE DO NOT KNOWINGLY COLLECT OR PROCESS PERSONAL DATA FROM INDIVIDUALS IN JURISDICTIONS WHERE SUCH COLLECTION OR PROCESSING WOULD BE PROHIBITED BY LAW.

International Data Transfers and Hosting. Although the Services are directed to users in the United States, our website and certain related infrastructure are hosted in Germany by our hosting provider (Mittwald), and personal information you provide may be transferred to, stored, and processed in Germany and other jurisdictions in which we or our service providers operate. Data protection and other laws in those jurisdictions may differ from the laws of your state or country. Where required by applicable law, we implement appropriate safeguards for cross-border transfers of personal information. By using the Services, you acknowledge that your information may be transferred to and processed in Germany and other locations as described in this Policy.

1.         INTRODUCTION AND PURPOSE

STW North America, LLC (referred to herein as “STW North America”, “STW”, “we”, “us”, and “our”) provides German-engineered automation technologies for mobile and off-highway machines, including rugged controllers, displays, sensors, I/O devices, telematics and connectivity hardware, and electrification and power-management components (such as e-machines, inverters, and battery management systems), together with related software, IoT, and cloud-connectivity tools, for original equipment manufacturers (OEMs), system integrators, and machine builders. We are committed to protecting the privacy and security of the personal information we collect and to being transparent about how we collect, use, share, retain, and delete that information.

This Privacy Policy (the “Policy”) describes our practices for handling personal information collected when you visit our website stw-na.com, contact us, request a quote or technical support, register for an account or portal, use our software, cloud, and telematics platforms, or otherwise use any other websites, platforms, or products and services that link to this Policy (collectively the “Services”).

This Policy does not apply to: (1) information collected by us that does not link to this Policy; (2) information collected by any third party, including through any application or content that may link or be accessible from our Services; or (3) any information governed by other privacy notices provided at the time of collection or by a third party that operates separate services (for example, third-party social platforms or payment processors with their own privacy policies).

2.         INFORMATION WE MAY COLLECT

We may collect the following types of personal information from you for the purposes described below. The categories of information we collect depend on how you interact with the Services (for example, request a quote, purchase products or Services, or use our software, cloud, and telematics platforms). We collect information directly from you, automatically from your device or browser, and from third-party service providers that process data on our behalf.

• Contact Information: When you contact us, request a quote, register for an account, or otherwise interact with us, we may collect your name, business email address, telephone number, mailing address, company name, job title, and other contact details necessary to provide the Services.
• Account Information: If you create an account or are provisioned access to our software, portals, or telematics and cloud platforms, we may collect account credentials (username and password), role information, profile information, and optional profile preferences.
• Device and Usage Information: We and our service providers may automatically collect device, browser, and usage information when you access or use the Services, including IP address, device identifiers, operating system, browser type and settings, referrer URL, access times, pages and content viewed, interaction events, and diagnostic data. This data helps us operate and secure our websites and platforms, deliver content, and troubleshoot issues.

• Cookies and Similar Technologies: We and our third-party partners use cookies, web beacons, pixels, and similar technologies to enable core functionality of the Services, remember preferences, and provide analytics and advertising (see the “Cookies and Similar Technologies” section below). Disabling cookies may limit functionality of the Services.
• Geolocation Information: Where permitted by your device settings, we may collect geolocation information (for example, IP-derived or device-provided location) when you interact with the Services. Location data helps us provide location-specific features and to detect suspicious activity.
• Communications Data: If you contact us, provide feedback, or otherwise communicate through the Services, we collect the subject matter of your message and any content you include, including support and warranty requests and other user-provided content, to support and improve the Services.
• Professional Relationship Information: If you interact with us as a vendor, partner, or business contact (for example, a supplier, distributor, or integrator), we may collect business contact information, business name, professional title, and other relevant business details to manage those relationships.
• Social Media Information: If you connect or log in with a third-party account or interact with us on social media platforms (such as LinkedIn), we may receive profile information you permit the platform to share, such as name, username, email address, and profile photo.
• Other Information: Any other information you voluntarily provide as part of your use of the Services, including information provided during account registration, purchasing, or support interactions, will be collected and used as described in this Policy.

You may choose not to provide certain personal information, but if you do not provide information required to provide a particular feature (for example, account creation, purchasing, or support), you may not be able to use that feature.

3.         HOW WE MAY USE YOUR INFORMATION

We may use the information described above in connection with the following purposes, and for any other purpose disclosed to you at collection or permitted by applicable law:

• Providing Our Services To You: We use your information to provide and operate the Services, including to fulfill orders for hardware and software, provision access to our portals, telematics, and cloud platforms, deliver connectivity and asset-management features, provide engineering, integration, and technical support, and facilitate purchases and deliveries of products and digital deliverables. We also use information to respond to support and warranty requests.
• Operating Our Business: We use personal information to run our business operations, which includes managing relationships with customers, vendors, and partners, maintaining backups and archives (including brief backup retention for recovery), managing administrative and internal workflows, obtaining professional services (legal, accounting, and compliance), obtaining insurance, and mitigating operational risks such as fraud, abuse, and security incidents.
• Communicating With You: We use your contact information to send transactional and operational communications (for example, order and shipping confirmations, account and support responses, product and security updates, and service notices), to provide customer service, and to communicate important changes to the Services. Marketing communications are described separately below and are subject to your choices and applicable law.
• Fraud, Security, Legal Enforcement and Compliance: We use information to protect the security and integrity of the Services and our users, to detect and prevent fraud or misuse, to enforce our Terms of Use and other agreements, to comply with legal process (for example, subpoenas or court orders), and to establish, exercise, and defend legal claims.
• Develop Insights: We analyze aggregated and individual usage data to improve and personalize the Services, to develop new products and features, and to measure and analyze user engagement and trends.
• Improving Your Experience,Marketing and Advertising: We may use information to market and promote our products and Services (for example, sending offers, newsletters, product announcements, and event or webinar invitations, or showing promotional material). We may publish customer stories, case studies, or testimonials only where we have obtained any necessary consent, and we reserve the right to remove any content that violates applicable requirements.
• Managing Our Business Relationships: We use information to administer and enforce our agreements with customers, vendors, partners, and other users, to perform due diligence where required, and to manage billing, orders, refunds, and other transactional matters.

We may also use information to accomplish other purposes related to or ancillary to the purposes described in this Policy, for which your personal information was provided, or for which we have a legal basis under applicable law. We may also create, disclose, and otherwise use de-identified or aggregated data (which is no longer treated as personal information) for analytics, research, and business purposes.

4.         HOW WE MAY DISCLOSE YOUR INFORMATION

We may disclose or share your information described above in the following contexts or as otherwise permitted by applicable law:

• Service Providers: We share personal information with third-party service providers that perform functions on our behalf or help us provide the Services. These providers include third-party services for hosting, storage, cloud and connectivity services, payment processing, analytics, customer relationship management, and workflow management. A current list of our key service providers and their functions is available upon request. These providers act as processors under contract and are permitted to use personal information only as necessary to perform their services for us.
• Corporate Affiliates: We may share personal information with our subsidiaries, affiliates, and their employees, agents, and representatives to the extent necessary for business purposes or as permitted by applicable law.
• Acquisition and Similar Transactions: If we are involved in a merger, acquisition, sale of assets, bankruptcy, or similar corporate transaction, your personal information may be transferred as part of the transaction. We will notify affected users as required by applicable law.
• In Response to Legal Process or Defending Legal Claims: We may disclose personal information as required by law, court orders, subpoenas, or other legal process, including to respond to any government or regulatory requests, or if we reasonably believe such action is necessary to comply with applicable law.
• Necessary Disclosure: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of STW North America, our customers, or others, we may disclose information. This includes exchanging information with other companies and organizations (such as payment processors, fraud prevention vendors, and other service providers) for the purposes of fraud protection, payment processing integrity, and credit risk reduction.
• Professional Advisors: We may share personal information with STW North America’s attorneys, accountants, fiduciaries, and consultants, as well as with third-party service providers (for example, hosting, cloud, connectivity, analytics, or payment providers such as Microsoft Azure) that need access to your information to provide operational, legal, financial, or other support on our behalf.
• With Your Consent or at Your Direction: From time to time, we may ask whether you would like us to share your personal information with unaffiliated third parties who are not described elsewhere in this Policy (for example, marketing partners, media distributors, or other vendors). We will disclose your information in this context only with your explicit permission or at your direction.
• Deidentified or Aggregated Data: We may share aggregated information, and information that does not identify any specific individual, such as groupings of demographic data and customer preferences, for compliance with reporting obligations; for business or marketing purposes; for product development and improvement; and to assist us and others in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, marketing, and/or functionality. Such deidentified or aggregated data does not identify you directly.

5.         COOKIES AND SIMILAR TECHNOLOGIES

Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your device and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your device until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website. You can block and control cookies using the information noted below. If you block all cookies, certain functionalities on the Platform may not work.

Other Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, pixels are small images on a web page or in an email that collect information about your browser or device and can set cookies. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

Web Beacons. Web beacons, also known as pixel tags or clear GIFs, are small strings of code that are embedded into web pages and your device that allow a website or application to count users and determine how long users visit web pages or applications.  We use web beacons for website traffic reporting, unique visitor counts, auditing and reporting, personalization, and other functions. 

Tracking Pixels.  A tracking pixel is a small piece of code we may use to collect and share information on your usage of our website, such as the pages that you have visited, or the way you have interacted with them. Through the tracking pixels, your browser automatically establishes a connection with the server of an online advertiser. In this way, the online advertiser receives information that you access on our website. This can allow us to ensure that we are serving ads that match your interests, when you are visiting any of the websites of the online advertiser, or a website that includes ads served by the online advertiser. If you are authenticated to an online advertiser using tracking pixels, e.g. by being registered and logged in to a social network, the online advertiser can assign the visit to our website to your account. The data we may collect through tracking pixels is anonymous and does not include any personal data of individual users.  We have no influence on the extent to which the data collected through the tracking pixels is used by the online advertisers and therefore direct you to their privacy notices. 

What Cookies and Similar Technologies Do We Use and Why Do We Use Them?

We use certain cookies and similar technologies to operate the Services, to measure and track how you interact with the Services, to ensure the privacy and security of our Services, to enhance your experience, to support account and purchasing flows, and to otherwise tailor our communications to you. Examples of third-party providers that may set or read cookies or use tracking technologies on our behalf include analytics providers (for example, Google Analytics), advertising platforms, and vendors that support hosting and cloud services (for example, Microsoft Azure). Note that some back‑end providers primarily process data server-side and may not rely on browser cookies in the same way as client-side analytics or advertising providers.

Some of our service providers may use cookies or other methods to gather information regarding your use of the Services and may combine the information in these cookies with personal information about you that you may have provided or that they may have through permissible means. Service providers that may set or receive information via cookies or similar technologies include our hosting and cloud infrastructure providers (e.g., Microsoft Azure), analytics providers, advertising partners, and CRM providers. How and when a third party uses that tracking information depends on their privacy policy, which you should review.

The cookies and similar technologies used on the Services include the following:

Essential: Essential cookies are strictly necessary for basic features and functionality of the Services and are used based on our legitimate interests in providing you with a functioning and secure service. Without these essential cookies, the Services will not perform properly, and we may not be able to provide you with certain Services you have asked for, provide access to secure areas, and choices you have made for better functionality cannot be provided. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into the Services, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into our Services.

Functionality: Functionality cookies help us customize content on the Services based on your preferences. We use functionality cookies to remember choices you’ve made or information you’ve provided, such as your username or the region you are in. This allows us to tailor your experience on the Services to your preferences. For example, authentication cookies are functionality cookies that are used for the duration of a session (or persistent, if you agree to the “remember me” function) to allow users to authenticate themselves on subsequent visits or gain access to authorized content across pages on the Services.

Analytics and Performance: We use analytics and performance cookies to collect information about how you use the Services, including which website pages you go to most often and if users receive error messages from certain pages in order to help us fix technical issues or errors and highlight areas where we can improve the Services. We also use these cookies to detect the most searched for words in search engines that lead to the Services. You may also encounter third-party analytics and performance cookies on our Services which may gather browsing activity (such as information you have entered or choices you have made) across numerous websites that you visit and across numerous browsing sessions. We will only enable such tracking with your explicit consent where required by applicable law. These cookies also help improve how our Services function and perform, customize your interaction with our Services, and help provide more relevant messaging and marketing communications to you.

Advertising: Advertising cookies and other similar technologies are used by us to enable us to understand your interests and tailor marketing to you and your interests and provide you with a more personalized service. These cookies remember that you visited our Services and we may share this information with third-parties, such as advertising platforms, so that we can show you relevant offers and direct personalized advertising to you. We may also use these cookies to target and re-target visitors to our Services with digital advertising that is most relevant to the user. These cookies are also used to limit the number of times you see an advertisement or particular content, as well as help measure the effectiveness of an advertising or marketing campaign.

We also use third-party digital tracking technologies on our Services and receive data from such technologies including, but not limited to, the following types of providers: analytics providers (for example, Google Analytics), hosting and cloud infrastructure providers (for example, Microsoft Azure), and advertising and measurement partners. The specific data collected and the manner in which it is used by each provider depends on that provider’s practices; while we require our service providers to maintain appropriate security measures, we are not responsible for their privacy practices. Please review their privacy policies for more information.

Matomo: We use a self-hosted instance of Matomo Analytics to understand how visitors use our website, measure website performance, and improve our content and services. Matomo is hosted on servers operated by us or on our behalf by Mittwald CM Service GmbH & Co. KG, Königsberger Straße 4-6, 32339 Espelkamp in Germany. Analytics data is stored in our own Matomo database and is not provided to Matomo for its independent use. Matomo may collect information about your use of the website, including pages viewed, links clicked, the date and time of your visit, referring URLs, browser type, operating system, device information, andan anonymized IP address. We use cookies or similar technologies through Matomo to recognize returning visitors and create website usage statistics. You can manage your preferences through Cookie Settings and may also adjust your browser settings to limit or block cookies. You may opt out of Matomo analytics tracking at any time by using the Link in the end of this page.If the Matomo opt-out feature is used, Matomo places an opt-out cookie in your browser to record that preference. We retain Matomo analytics data for 14 months after which it is deleted or anonymized. Further information regarding your rights as a data subject and the contact details of the data controller or data protection officer can be found in the other sections of this Privacy Policy.

Google Analytics. Where you have explicitly consented through our cookie banner or have not disabled third-party advertising cookies (depending on your location),we use Google Analytics to collect and process statistical data about the number of people using the Services and to better understand how they find and use the Services. The data collected may include device and browser characteristics, IP address (which may be truncated or pseudonymized), and on‑site activities to measure and report statistics about user interactions. We may also use additional analytics or tag management services (for example, Segment or Mixpanel) consistent with your consent. Any data collected by these tools is used in accordance with this Policy and Google’s Privacy Policy. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy. You can learn more about Google’s advertising services by visiting its Technologies page along with information on Google Analytics.

You can opt‑out of Google’s use of cookies or device identifiers by visiting Google’s Ads Settings. You can also manage or block third-partycookies through your browser settings or change your consent choices in our cookie banner; doing so may affect the functionality of the Services.

You can also opt-out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on feature. For more details, visit the Google Analytics Opt-out Browser Add-on page. Managing cookies through your browser or the cookie banner on our Services may likewise prevent Google Analytics collection.

Social Media and Advertising Platforms. We may use social media and advertising platforms (for example, LinkedIn and Google) to promote our products and Services and to measure the effectiveness of our marketing. These platforms may use cookies, pixels, or similar technologies that identify your browser or device and report certain information about your interactions with our ads and Services. Where required by law, we rely on your consent for advertising cookies and similar technologies. We do not sell personal information for money; however, certain sharing for advertising and analytics may be considered a “sale,” “sharing,” or “targeted advertising” under applicable law, and where required we offer the opt-out mechanisms described below.

How Do Our Advertising and Marketing Partners Use Cookies for Interest-Based Advertising?

STW North America may use third parties — including advertising networks, social platforms, and other content providers (for example, LinkedIn and Google) — to serve targeted ads on our Services and on other websites and apps. This practice, often called interest-based advertising, may involve cookies and similar technologies that uniquely identify your browser or device and report certain information about your visits to our Services and other sites (for example, pages visited and responses to ads). We and our advertising partners use this information to measure and improve the effectiveness of our marketing and to deliver ads that are more relevant to people likely to be interested in our products and services.

Some third-party providers may combine information collected from our Services with information they obtain from other websites or services to create a more complete profile about browsing activity and interests. STW North America does not control these third parties’ tracking technologies or how they use the information they collect. If you have questions about interest-based advertising or wish to exercise choices with respect to a particular advertising provider, please consult that provider’s privacy resources and opt-out tools as described below.

How Can You Opt-Out from Interest-Based Advertising?

Some advertising networks and third-party advertising companies we may work with participate in industry opt-out programs such as the Digital Advertising Alliance (“DAA”) or the Network Advertising Initiative (“NAI”). Visit the sites below to learn more about interest-based advertising and to opt out of receiving personalized advertising from participating companies:

Digital Advertising Alliance:        https://optout.aboutads.info/?lang=EN&c=2#!%2F

National Advertising Initiative:    https://optout.networkadvertising.org/?c=1#!%2F

Please note that opting out through these resources prevents participating companies from delivering tailored ads to the specific browser or device where you opt out, but it does not necessarily stop all advertising. To successfully opt out you must have cookies enabled; your opt-out applies only to the browser and device where you complete the opt-out, and if you delete browser cookies you may need to opt out again.

Choices About Cookies

Most web browsers are set to accept cookies by default. You may change your browser settings to refuse or alert you about cookies, but doing so may affect the functionality of our Services. After changing your cookie settings, you may need to clear existing cookies to remove previously stored identifiers; consult your browser’s help resources for details.

If you decline the use of cookies, certain features of the Services — including account sign-in, maintaining a session, and personalized elements of our platforms — may not function correctly. Your cookie preferences are browser- and device-specific, and if you clear cookies you may need to reapply any opt-out or preference choices.

The links below provide information about how to disable or manage cookies. These third-party links are provided for your convenience; STW North America does not control the content of these external sites.

Google Chrome:         https://support.google.com/chrome/answer/95647?hl=en

Firefox:                       https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Internet Explorer:      http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies

Safari; iOS:                 https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265

Microsoft Edge:          https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-  edge-63947406-40ac-c3b8-57b9-2a946a29ae09

For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. STW North America will respond to “Do Not Track” or similar signals to the extent required by applicable law. To learn more about “Do Not Track,” visit http://www.allaboutdnt.com.

Opt-Out Preference Signals: We recognize and honor opt-out preference signals sent through browser- or device-based technologies, such as the Global Privacy Control (GPC), in accordance with applicable privacy laws. If your browser or device is configured to send an opt-out preference signal (such as GPC), STW North America will treat that signal as a valid request to opt out of the sale or sharing of personal information and/or targeted advertising for the specific browser, device, or user associated with the signal, where permitted or required by law. You do not need to take additional action beyond enabling a compatible signal in your browser or extension. To learn more or activate a signal like GPC, visit https://globalprivacycontrol.org.

Please note that our response to opt-out preference signals may vary depending on your state or country of residence and the legal requirements that apply (for example, consumers in California have specific rights under the CCPA/CPRA that may affect how we respond to signals or requests).

6.         RETENTION OF PERSONAL INFORMATION

We retain and use your information for only as long as necessary to fulfill the purposes for which it was collected, subject to the specific retention practices described below, to comply with our legal obligations, to resolve disputes, to protect our rights, to provide the Services, and to enforce our agreements. Telematics, machine, account, and usage data are retained while your account or the applicable service subscription remains active, or as needed to provide the Services and to meet legal or operational needs. Where we process telematics or machine data on behalf of a customer, retention is governed by our agreement with that customer. We may modify these retention periods as needed for operational, technical, or legal purposes. We will provide advance notice of material changes to retention periods when possible, though immediate changes may be required in certain circumstances such as for security or legal compliance.

We take reasonable steps to delete personal information when: (1) we have a legal obligation to do so; (2) we no longer have a business purpose for retaining it; or (3) you request deletion and we determine that deletion is appropriate under applicable law. When you delete content or close your account, we will remove that information from our active servers and user-facing systems. However, copies may remain in backup and archival systems for a commercially reasonable period (to the extent permitted by law), and we may retain information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. Some records (for example, audit logs, aggregated/anonymous analytics, or copies incorporated into completed transactions or deliverables) may persist as described elsewhere in this Policy.

To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, analytics, product and service improvement, and other legitimate business purposes. Such anonymized data will not be used to re-identify you except as permitted by applicable law.

7.         SECURITY AND PROTECTION OF PERSONAL INFORMATION

We recognize the importance of safeguarding your personal information and endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards to protect your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. These measures include industry-standard safeguards such as encryption in transit and, where applicable, at rest, role-based access controls, monitoring and logging, secure development practices, and contractual controls with our subprocessors (for example, Mittwald for website hosting in Germany and Microsoft Azure, Amazon Work Space (AWS) for cloud and telematics services). Our employees and contractors are subject to confidentiality obligations. We implement industry-standard security measures and continuously work to protect your information. While no system can guarantee absolute security, we maintain robust safeguards designed to protect your data in accordance with applicable laws and industry best practices.

While our security measures seek to protect your information in our possession, no security system is perfect, and no data transmission is 100% secure. Any transmission of personal information is at your own risk. We cannot guarantee or warrant the security of any information transmitted to or from the Services, including via our websites, platforms, or other web interfaces. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

8.         YOUR RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights under this Policy. If you would like to access, manage, correct, limit, or request deletion of your personal information, or if you no longer wish to receive marketing communications from us, you may submit requests via the contact information below. We will honor such requests to the extent required by applicable law and subject to any legal exceptions or operational needs (e.g., for backup restoration, fraud prevention, or dispute resolution).

Email Opt-Out. If you no longer wish to receive marketing communications from STW North America via email, you may opt out by clicking the “unsubscribe” link at the bottom of our marketing emails or by contacting us at info@stw-na.com and providing your name and email address so that we may identify your account. Once we receive your instruction, we will promptly take reasonable steps to honor your request.

Cookies: You may set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Additionally, our Services may present a cookie or privacy preference banner that enables you to manage certain cookie and tracking preferences. Our Services may also use local storage and similar technologies. We and our third-party analytics and advertising partners may use cookies, web beacons, and similar technologies to collect information about your use of the Services to help operate and improve the Services, perform analytics, and deliver relevant content and advertising. For details about the specific categories of cookies we use and how to control them, please consult our Cookie Notice (if available) or contact us at info@stw-na.com.

Accuracy and Updating Your Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please update it in your user/account profile where applicable, or let us know via info@stw-na.com. We are not responsible for losses arising from inaccurate, incomplete, or outdated personal information that you provide to us.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us at info@stw-na.com so that we may investigate and attempt to resolve your concerns.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about certain categories of information we have shared with third parties for direct marketing purposes, if any. Not all information sharing is covered by “Shine the Light” requirements; only information on covered sharing, if any, will be included in our response. To make a “Shine the Light” request, contact us at info@stw-na.com.

9.         INDIVIDUAL RIGHTS

To the extent you are a resident of certain U.S. states with comprehensive privacy laws, you may have one or more consumer rights where authorized by applicable state law. These rights may include the ability to request access to certain personal information we maintain about you, request correction or deletion of personal information, request portability of certain data, opt out of certain profiling and targeted advertising activities, and limit the use or disclosure of sensitive personal information where defined by law. To exercise these rights, or for more information about which rights apply to you, contact us at info@stw-na.com. We will verify and respond to requests in accordance with applicable legal timing and identity verification requirements.

• Right to Access. Subject to certain conditions set forth in applicable U.S. state privacy laws, you have the right to confirm whether we are processing your personal information, to know what personal information we have collected about you and receive a copy of such information in a portable format, the purposes for which we collect your personal information, categories of recipients to whom we disclose your personal information (which may include our service providers such as hosting, cloud, and payment providers), categories of sources of collection, and other information required by applicable law.
• Right to Correct. Subject to certain conditions and exceptions set forth in applicable U.S. state privacy laws, you have the right to request that we correct any inaccurate personal information that we have collected about you. You may request corrections by contacting info@stw-na.com and following the verification steps we require.
• Right to Delete. Subject to certain conditions and exceptions set forth in applicable U.S. state privacy laws, you have the right to request that we delete the personal information we have collected about you. We will comply with deletion requests as required by law, subject to exceptions (for example, for information necessary to complete a transaction, to comply with a legal obligation, to detect and prevent fraud, or to maintain backup copies for a commercially reasonable period as described in this Policy).
• Right to Opt-Out. Subject to certain conditions set forth in applicable U.S. state privacy laws, you have the right to opt out of targeted advertising, profiling, or the sale or sharing of your personal information, to the extent such activities occur and are defined under applicable law. STW North America does not sell your personal information. If you wish to exercise opt-out rights, contact info@stw-na.com.
• Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of your rights under any applicable U.S. state privacy laws.
• Right to Appeal. To the extent applicable state law provides such a right, you may appeal our decision to deny your request. We will respond within the timeframes required by applicable law and may extend the response period to the extent authorized by law.
• Right to Limit Use and Disclosure of Sensitive Personal Information. If applicable state law classifies certain categories of personal information as “sensitive personal information” or similar, we will limit our use and disclosure of such information to what is reasonably necessary to provide the Services, as permitted by law, or as otherwise disclosed at collection.

If you have questions or would like to exercise your consumer rights (to the extent available under applicable U.S. state privacy laws), please contact us at info@stw-na.com. We will verify your identity and process your request in accordance with applicable law.

Individuals in the European Economic Area, the United Kingdom, and Switzerland

The Services are directed to the United States market. We do not intend to offer or market the Services to, or to monitor the behavior of, individuals located in the European Economic Area, the United Kingdom, or Switzerland, and the Services are not intended for use by such individuals. Although our website and certain related infrastructure are hosted in Germany, we use that infrastructure solely to deliver the Services to our United States audience and implement appropriate safeguards for personal information stored or processed there. If you are located in the European Economic Area, the United Kingdom, or Switzerland, please do not use the Services or provide personal information to us. If you believe we have inadvertently collected your personal information in a manner subject to the EU or UK General Data Protection Regulation or comparable Swiss law, please contact us at info@stw-na.com and we will address your request as required by applicable law.

10.       THIRD‑PARTY WEBSITES

This Policy applies to the STW North America Services and does not govern the privacy or security practices of third-party websites or applications. The Services integrate with third-party service providers (for example, Microsoft Azure for hosting and cloud services and third-party payment processors) and with analytics, CRM, and customer support vendors. Those providers have their own privacy policies that govern their handling of your information, and we encourage you to review their respective privacy policies. When you interact with content we publish to third-party platforms (for example, posts on LinkedIn, YouTube, or other channels), those platforms’ terms and privacy practices will apply to that content as published there.

The Services may contain links to, and media or other content from, third parties. Where we publish content on public third-party platforms, such content may be viewable globally and subject to the policies of those third-party platforms. If you click an embedded third-party link, you will be redirected away from the Services to the external website, and you should review that site’s privacy policy and terms before providing personal information.

We expressly disclaim any responsibility for and do not (1) guarantee or warrant the adequacy of the privacy or security practices employed by third parties, (2) control third parties’ independent collection or use of your information, or (3) endorse third-party content, products, or services accessed through embedded links. Any information you provide to a third party will be governed by that party’s privacy policy and terms. If you are unsure whether a website or application is controlled by STW North America, please contact us at info@stw-na.com.

11.       CHILDREN’S PRIVACY

STW North America’s Services are intended for businesses and their representatives and are not directed to children. We do not knowingly collect personal information from children under the age of 13 (or the applicable age of digital consent in your jurisdiction). If we learn that we have collected personal information from a child without appropriate consent, we will take steps to stop collecting that information and delete it. If you believe we have collected personal information from a child in violation of this Policy, please contact us at info(at)stw-na.com and we will take steps to remove such information as required by applicable law.

For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.

12.       UPDATES AND CHANGES TO THIS POLICY

We may add to, change, update, or modify this Privacy Policy from time to time. We will post any changes to this Privacy Policy on this page and such changes will be effective upon posting, unless otherwise stated. If we make material changes, we will provide notice through the Services (for example, an in-app notice or a notice on the homepage) and may also notify you by email to the extent we have your contact information. The date that this Privacy Policy was last updated appears at the top of the Policy. Your continued use of the Services after the “Last updated” date constitutes your acceptance of and agreement to the revised Privacy Policy. If you do not agree to the changes, you should stop using the Services.

13.       CONTACT US

For more information, or if you have any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact STW North America using the information below. If your communication contains sensitive personal information, you may wish to contact us by postal mail; however, email (below) is the preferred and fastest method for privacy requests.

In Writing:   STW North America, LLC        

                     Attn: Privacy

                     5126 South Royal Atlanta Drive

                     Tucker, GA 30084, U.S.A.

By Email:  info@stw-na.com