Privacy Policy

Last Updated: June 1, 2024

Introduction

Bonnell Aluminum and its subsidiaries (collectively “Bonnell”, “we,” “us”) respect your privacy concerns. This Privacy Policy includes a description of the types of information Bonnell may collect on this website and other websites or apps that link to this Policy (collectively, the “Services”), how we may use the information, and with whom we may share the information. We also describe your rights, the measures we take to protect the security of the information and how you may contact us about our privacy practices.

If you are a California consumer, please see the section of this Privacy Policy called “California Consumer Privacy Statement” for more information about your privacy rights.

Our contact details can be found in the “How to Contact Us” section at the end of this Policy. Click on one of the links below to jump to the listed section:

• Information We Obtain
• How We Use Information We Obtain
• Information We Share
• Your Rights and Choices
• How We Protect Personal Information
• Children’s Privacy
• Links to Third-Party Services and Features
• Updates to Our Privacy Policy
• How to Contact Us
• California Consumer Privacy Statement

Information We Obtain

We may obtain information about you in various ways, such as when you use our Services or otherwise interact with us (for example, by calling or emailing us). The types of information we may obtain include:

• Contact information (such as name, postal address, email address, and telephone number);
• Account information, such as login information, account preferences and other account details;
• Payment information (such as your name, billing and delivery address, and payment card and other payment and financial details);
• Information you submit in connection with a career opportunity at Bonnell, such as such as your job title, work history, business reference information, and professional and employment background, your résumé and any additional job application information you provide to us;
• Social media information, such as your social media handle; and
• Other personal information you choose to provide, such as through emails or other communications, social media pages, surveys, registrations and sign-up forms.

When you use our Services or open our emails, we may obtain certain information by automated means, such as cookies, pixel tags, server or device logs and other technologies. A “cookie” is a text file that websites send to a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser. A

“pixel tag” (also known as a web beacon), which is a type of technology that is often used in combination with cookies, is placed on a website or within an email to track certain activity, such as views of a website or when an email is opened. These technologies help us to (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with the Services; (3) tailor the Services around your preferences; (4) measure the usability of the Services and the effectiveness of our communications; (5) authenticate your identity, protect against fraud and provide our products and services; and (6) otherwise manage and enhance our products and services, and help ensure they are working properly.

We may use cookies and similar technologies to automatically collect personal data about your device, browsing actions and usage patterns. For example, we may collect information about your device and web browser in this manner such as your device Internet Protocol (“IP) address, general location information, device type and characteristics, browser type and characteristics, operating system type and version, language and country preferences, usage statistics, referring emails and web addresses, and other application details. We also may obtain information about your interactions with our Services, such as pages visited, links clicked, features used, dates times and duration of your visits, session information, clickstream data and other information about your use of our Services.

Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that disabling, blocking, or deleting these technologies may impact your ability to fully use our Services. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

How We Use Information We Obtain

We may use the information we obtain to:

• Provide our products and services, including processing, fulfilling orders, and providing client support such as repairs and other services;
• Manage your account;
• Personalize your experience with our products and services;
• Advertise and market our products and services;
• Administer participation in surveys, promotions or other programs;
• Perform market, trend or statistical research;
• Compile, anonymize or aggregate personal data for our business purposes;
• Operate, evaluate, and improve our business (including developing new products and services; analyzing and improving our products and services; managing our communications; managing collections and credit risk; performing data analytics; and performing accounting, auditing, and other internal functions);
• Manage career opportunities, including for recruitment purposes, employee onboarding, and other Human Resources purposes;
• Manage our relationships with current or prospective partners, clients and vendors and other business partner personnel;
• Communicate with you, respond to your inquiries and offer client support, including repair and other services;
• Maintain and enhance the safety and security of our products and services, prevent misuse and troubleshoot technical issues;
• Verify your identity and protect against, identify, and prevent fraud and other unlawful activity, claims, and other liabilities;
• Comply with and enforce relevant industry standards, and contractual obligations; and
• Comply with and enforce applicable legal requirements and for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We also may use the information in other ways for which we provide specific notice at the time of collection.

Third-Party Analytics Services

We may use third-party analytics services on the Services, such as Google Analytics. The providers of these analytics services use technologies such as cookies and web beacons to help us analyze your use of the Services. The information collected through these means may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit Google’s Privacy and Terms Page and Google’s Opt-Out Help Page.

Interest-Based Advertising

You may see our ads on other websites because we use third-party ad services on our Services. Through these ad services, we can tailor our messaging to users considering demographic data, users’ inferred interests and browsing context. These ad services track information about your online activities over time and across third-party websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. These ad services may collect data about your visits to websites and apps that participate in these services, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place both on our Services and on third-party websites and apps that participate in these ad services. These ad services use this information to show you ads that may be tailored to your individual interests. This process also helps us track the effectiveness of our marketing efforts. Our Services are not designed to respond to “do not track” signals from browsers.

To learn how to opt out of interest-based advertising, please visit the Digital Advertising Alliance’s YourAdChoices Page, the National Advertising Initiative’s Opt Out Page, and TrustArc’s Your Advertising Choices Page.

Information We Share

We may share the categories of personal information we obtain about you (as described above) with the categories of third parties listed below:

• Our subsidiaries and affiliates;
• Third-party service providers, such as companies that provide us with technology and communications services, payment processing and billing services, advertising and marketing services, and other services; and
• Social media platforms if you use those services to connect with us.

We may also disclose personal information:

• If we are required to do so by law or legal process;
• In response to requests by government agencies, such as law enforcement authorities;
• To establish, exercise or defend our legal rights;
• When we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss;
• In connection with an investigation of suspected or actual fraudulent or illegal activity;
• In the event we sell or transfer (or contemplate the sale or transfer of) all or a portion of a business or assets to a third party, such as in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation; or
• Otherwise with your consent or as directed by you or your representative.

Your Rights and Choices

Bonnell provides you with choices in connection with the personal information we may collect. To update your preferences, limit the communications you receive from us, or make an inquiry, please contact us as indicated in the How to Contact Us section of this Privacy Policy. You can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

If you are a California resident, please see the California Consumer Privacy Statement section of this Privacy Policy for more information about your privacy rights.

How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Children’s Privacy

The Services are designed for a general audience and are not directed to children. In connection with the Services, we do not knowingly solicit or collect personal information from children under the age of 13. If you believe that a child under age 13 may have provided us with personal information, please contact us as specified in the How to Contact Us section of this Privacy Policy.

Links to Third-Party Services and Features

For your convenience and information, the Services may provide links to other online services (such as websites or social media platforms), and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Bonnell, we are not responsible for these third parties’ information practices.

Updates to Our Privacy Policy

We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our personal information practices. For significant changes, we will notify you by posting a prominent notice on the website. We will indicate at the top of the Privacy Policy when it was most recently updated.

How to Contact Us

You can update your preferences, ask us to remove your information from our mailing lists, submit a request or ask us questions about this Privacy Policy by contacting us at:

Bonnell Aluminum

1100 Boulders Parkway
North Chesterfield, VA 23225, USA
Email: privacy@bonnellaluminum.com

California Consumer Privacy Statement

Last Updated: June 1, 2024

This California Consumer Privacy Statement ("Statement") supplements the Bonnell Privacy Policy. This Statement applies solely to personal information collected about California consumers, such as our customers, website visitors, attendees of our webinars, trainings and/or other Bonnell events, business partners and job applicants. This Statement does not apply to Bonnell’s personnel.

This Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).

Notice of Collection and Use of Personal Information

In the course of business, we may collect, and may have collected during the 12-month period prior to the Last Updated date of this Statement), the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as device identifiers; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; unique pseudonym; user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, login credentials, account name, Social Security number, driver’s license number, passport number and other similar identifiers
• Personal information described in Section 1798.80 of the California Civil Code: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, age, gender, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: audio, electronic, visual, or similar information;
• Employment Information: professional or employment-related information, such as business contact information, résumé information, occupation details, education details, certifications and professional associations, previous employment details, emergency contact information, pre-employment screening and background check information, including criminal records information
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use, and may have used during the 12-month period prior to the Last Updated date of this Statement, the categories of personal information listed above for the purposes described in the Bonnell Privacy Policy and for the following business purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
• Providing advertising and marketing services to you, except for cross-context behavioral advertising (which is addressed in the Sale or Sharing of Personal Information Section below);
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us;
• Helping to ensure security and integrity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
• Undertaking internal research for technological development and demonstration;
• Managing career opportunities with us; and
• Managing our relationships with current or prospective partners, corporate customers and vendors, and other business partner personnel.

Bonnell does not collect or process sensitive personal information with the purpose of inferring characteristics about consumers.

To the extent we process de-identified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in the Bonnell Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account our legal obligations and our records retention requirements pursuant to Bonnell’s Records Management Policy and Schedule.

Sources of Personal Information

• During the 12-month period prior to the Last Updated date of this Statement, we may have obtained personal information about you from the following categories of sources: Directly from you, such as when you complete a Bonnell form or survey, attend our events (including any webinars or trainings), or otherwise contact us
• From your devices, such as when you interact with our website, products, and other online services
• Our affiliated entities and subsidiaries
• Service providers, contractors, and vendors who provide services on our behalf
• Publicly available sources and databases;
• Other individuals, such as referrals
• Online advertising services and advertising networks
• Social networks
• Our business partners
• Data brokers, such as background check services
• Recruiting and talent agencies
• Job references, such as your employers
• Data analytics providers
• Internet service providers
• Operating systems and platforms
• Government Entities

Sale or Sharing of Personal Information

We do not sell your personal information in exchange for monetary compensation. We may disclose your personal information by allowing certain third parties (such as online advertising services, advertising networks and social networks) to collect personal information via automated technologies on our websites and apps for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these types of disclosures of your information.

We may sell or share for cross-context behavioral advertising purposes, and may have sold or shared during the 12-month period prior to the Last Updated date of this Statement, the following categories of personal information about you to online advertising services, advertising networks and social networks:

• Identifiers
• Commercial Information
• Online Activity
• Inferences

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this Statement, we may have disclosed personal information about you to government entities (e.g., in response to law enforcement requests) and third parties in connection with corporate transactions (e.g., mergers, acquisitions, joint venture, reorganization, divestitures, dissolution or liquidation).

California Consumer Privacy Rights

You have various choices regarding your personal information, as described below.

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• Correction: You have the right to request that we correct the personal information we maintain about you if that information is inaccurate.
• Deletion: You have the right to request that we delete certain personal information we have collected from you.
• Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
• Shine the Light: Under California Civil Code § 1798.83, residents of California may request us to provide them with (a) a list detailing the categories of personal information that we may have disclosed to third parties for their direct marketing purposes during the preceding calendar year, and (b) the identities of those third parties, with certain limitations.

How to Submit a Request

To submit an access, correction, or deletion request, please email us at privacy@bonnellaluminum.com with “Personal Information Request” in the subject line and provide full details about your request, including the type of request you are making, that you are making a request to Bonnell, and your contact information. To submit a Shine the Light request, please email us at privacy@bonnellaluminum.com with the subject line “Shine the Light Request” and provide full details about the request. You can opt-out of the sale or sharing of your personal information by visiting our “Do Not Sell or Share My Personal Information ” option or broadcasting the Global Privacy Control (“GPC”) signal. Like with other types of browser-specific controls, if you use the GPC, we will process it for the browser from which you submit the request, but the opt-out request will not apply outside of the browser to your device or account. For more information about the GPC, please visit https://globalprivacycontrol.org. To submit a request as an authorized agent on behalf of a consumer, please email us at privacy@bonnellaluminum.com with the subject line Authorized Agent Request and provide full details about the request.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with certain other types of privacy requests. If you have an individual online account with us, we may verify your identity by requiring you to sign into your account. If you do not have an individual online account with us, we may require you to provide certain information to verify your identity, such as name, email address, phone number, company name, and/or an indication of your prior contact with Bonnell, depending on the information we have about you. In addition, if you do not have an individual online account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

If you designate an authorized agent to make a request on your behalf, depending on whether you have an individual online account with us, we may require that you verify your identity as set forth above. We also may require you to provide the authorized agent a written confirmation that you have authorized the agent to act on your behalf and the scope of such authorization.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. For questions or concerns about our privacy policies and practices, please contact us at as described in the “How to Contact Us” section of the Bonnell Privacy Policy.