PRIVACY POLICY

Smith System Mfg. Co. (“Smith System”) makes reasonable efforts to protect the privacy of your personal information. This privacy policy was created to demonstrate our commitment to fair information practices. This policy covers Smith System’s use of personal information that it collects when you use the website at http://smithsystem.com (the “Site”). Smith System complies with the U.S.-EU 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. Smith System has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit: http://www.export.gov/safeharbor. Smith System periodically conducts objective reviews of its privacy policy and procedures to ensure continued compliance with the Safe Harbor Privacy Principles.

1. Types of Information Collected

    a. Personal Information Collected. There are areas on the Site where you can share information that is unique to an individual; such as your name, company name, postal address, e-mail address, phone number, and zip code (collectively “Personal Information”). We ask for this information in order to deliver requested materials to you, respond to your questions, or deliver a product. If you communicate with us by e-mail or complete online forms, we may require Personal Information that personally identifies you. Smith System may also request your e-mail address or mailing address for the purposes of having someone contact you for additional information, or in response to your request for information from us.
    b. Information from Children. Smith System does not knowingly solicit or collect information from anyone under 13 years of age. We ask that anyone under 13 years of age not submit information to us. When we e-mail information to you, we will provide prominently displayed instructions that show you how to unsubscribe from receiving such information. If your child subscribes to receive information from Smith System without your knowledge, simply follow the instructions on our e-mail and unsubscribe immediately. Parents can also contact our customer service department to access, change, or delete the Personal Information that has been submitted by a child.
    c. Cookies and Tracers. Smith System may collect information about you and your use of our Site whenever you visit this Site. For instance, we may collect various forms of information such as entry and exit points for our Site (i.e., referring URLs or domain names), site traffic statistics, operating system and browser type (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. In addition, when you request pages on our Site, our servers automatically log your IP address. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. Smith System may store some information on your computer in the form of a “cookie” or similar file to help us maintain and improve this Site in many ways. A “cookie” is a small amount of data that is transferred to your browser by a Web server and can only be read by the server that gave it to you. It functions as your identification card, recording such things as Internet addresses, passwords, and preferences. It cannot be executed as code or deliver viruses. With most Internet browsers, you can erase “cookies” from your computer hard drive, block all “cookies,” or receive a warning before a “cookie” is stored. The “Help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please refer to your browser instructions to learn more about these functions. Enabling cookies allows you to take full advantage of all the features on the Site and we recommend that you leave them turned on. If you elect to block the cookies, we will not be able to provide you with a personalized experience on our Site.

    In some instances, Smith System may use tracking scripts or “tracers” that recognize a unique identifier from a cookie placed on your hard drive by another website. These are used by Smith System solely to gauge the success of our own advertising. For instance, Smith System may use a tracer to determine whether you visit certain Web pages where Smith System may have placed a banner ad. Smith System does not use tracers to gather information on your use of the Internet unrelated to Smith System. Please note that Smith System does not use tracers to identify your personal information, and you remain anonymous unless and until you communicate with Smith System via e-mail or complete on-line forms.

    BY ACCESSING OR USING THE SITE, YOU CONSENT TO SMITH SYSTEM’S USE OF COOKIES ON YOUR COMPUTER OR MOBILE DEVICE HARD DRIVE.

    d. Do Not Track Signals. The Site does not respond to Do Not Tack signals.

2. Use of Information Collected

Smith System will use the Personal Information directly submitted by you for the purpose that you have provided it. Smith System may also use the information you provide to us to contact you for reasons related to your original communication to us. Smith System may use your Personal Information to customize your experience on the Site and display content that we think you might be interested in according to your preferences. Your e-mail address is not used for any other purpose except to the extent necessary to follow-up on specific questions requiring information from Smith System. Visitors who give us their telephone numbers online will only receive telephone contact from us for reasons related to the visitor’s original communication or request. Smith System may use non-identifying and aggregate information to better design the Site.

3. Sharing of Personal Information

Smith System will not sell, rent, share, monitor, edit, or disclose any Personal Information about you, including its contents or your use of the Site, without your prior consent. From time to time, Smith System may engage other companies and individuals to perform functions such as conducting contests, sending postal mail and e-mail, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), and providing customer service. Such companies shall only use your Personal Information for those purposes required to perform their functions. However, you will have the opportunity choose not to have your Personal Information shared with these third-parties.

Smith System may share your Personal Information, without your prior consent, for the limited purposes noted below:

    a. Business Transfers. As Smith System continues to develop its business, we might sell or buy subsidiaries or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the obligations made in any pre-existing privacy policy.

    b. Legal Obligations. Smith System may share your Personal Information if we have a good faith belief that such action is necessary to: (i) comply with legal process or other legal requirements of any governmental authority; (ii) protect and defend the rights or property of Smith System; (iii) enforce this Privacy Policy; (iv) protect the interests of other users of the Site or any other person; or (v) operate or conduct maintenance and repair of the Site or equipment.


4. Protection of Personal Information

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, Smith System has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Information Smith System collects.

5. Privacy Complaints by European Union Citizens:

In compliance with the Safe Harbor Principles, Smith System commits to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should first contact Smith System at:
Smith System Mfg. Co.
P.O. Box 860415
Plano, Texas 75086
Telephone: 1-800-328-1061
E-mail: marketing@smithsystem.com

Smith System has further committed to refer unresolved privacy complaints under the Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Smith System, you may contact the BBB EU SAFE HARBOR program at the address below:
Council of Better Business Bureaus, Inc.
BBB EU SAFE HARBOR
4200 Wilson Boulevard, Suite 800
Arlington, VA 22203
Phone: 703-276-0100
Web: www.bbb.org/us/safe-harbor-complaints

6. Other Limits to Your Privacy

The Site may contain links to other non-Smith System websites. Smith System is not responsible for the privacy or security practices, or the content of such websites. Smith System has no control over the use of such websites and you should exercise caution when deciding to disclose any Personal Information on these websites.

7. User Choice Regarding Collection, Use, and Distribution of Personal Information

You may choose not to provide Smith System with any Personal Information. In such an event, you will be only able to access of the Web pages of the Site. If you do not wish to receive information and promotional material from us, you may select the appropriate “opt-out” option each time we ask you for Personal Information.

8. How You Can Access Or Correct Your Information

If you have provided your Personal Information and your Personal Information changes (such as your address or telephone) or you want to delete your account, email: marketing@smithsystem.com or click unsubscribe from any email you have received from Smith System. To protect your privacy and security, Smith System may also take reasonable steps to verify your identity before granting access or making corrections.

9. Updates and Changes to Privacy Policy

Smith System reserves the right, at any time, to add to, change, update or modify this Privacy Policy, by posting such change, update or modification on the Site. Any such change, update or modification will be effective immediately upon posting on the Site and notice of the change will be sent to you. Updates and changes to the Website Terms and Conditions of Use Agreement and the Privacy Policy will continue to govern your use of the Site even if you elect not to receive notice of such changes.

10. How to Contact Us

Should you have other questions or concerns about our Privacy Policy, please send Smith System an e-mail to marketing@smithsystem.com.

9754948v2

Close

Smith System

Close