PERSONNEL POLICIES AND PROCEDURES MANUAL
POLICY X-XX
US-EU PRIVACY SHIELD PRIVACY POLICY
This US-EU Privacy Shield Privacy Policy (the “Policy”) applies to the following entities:
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Allied Motion Technologies Inc.
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Emoteq Corporation
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Motor Products Corporation
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Stature Electric Inc.
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Globe Motors, Inc.
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Globe Motors de Mexico S.A. de C.V.
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Allied Motion Technologies BV
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Allied Motion Dordrecht BV
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Allied Motion Stockholm AB
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Allied Motion Portugal Lda
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Allied Motion Ferndown Ltd.
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Ostergrens Elmotor GmbH
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Allied Motion Canada, Inc.
The entities listed above are collectively referred to hereinafter as “Allied Motion.”
Allied Motion complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department
of Commerce regarding the collection, use, and retention of personal information transferred from the
European Union and Switzerland to the United States, respectively. Allied Motion has certified to the
Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between
the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall
govern. To learn more about the Privacy Shield program, and to view our certification, please visit
https://www.privacyshield.gov/.
Note: It is incumbent on the individual Allied Motion locations and Technology Units to identify
additional local and/or regional regulations and ensure compliance with such.
Allied Motion has certified that it adheres to the EU-US Privacy Shield Principles as follows:
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Notice
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Approved:
Effective Date: XX/XX/XXXX
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President and CEO
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PERSONNEL POLICIES AND PROCEDURES MANUAL
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Choice
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Accountability for Onward Transfer
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Security
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Data Integrity and Purpose Limitation
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Access
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Recourse, Enforcement and Liability.
POLICY X-XX
To learn more about the Privacy Shield program, and to view Allied Motion’s certification, please
visit https://www.privacyshield.gov/welcome.
SCOPE
This Policy applies to all Personal Data and Personal Information (both as defined below) transferred
from countries in the EU to the US by or on behalf of Allied Motion.
DEFINITIONS
“EU Directive” is the EU comprehensive privacy legislation, Directive 95/46/EC on Data Protection, that
became effective on October 25, 1998. The Directive requires that transfers of personal data take place
only to non-EU countries that provide an “adequate” level of privacy protection.
“Personal Data” and “Personal Information” are data about an identified or an identifiable individual that
are within the scope of the EU Directive, that is received by Allied Motion in the US from the EU, and
recorded in any form. It does not include anonymized data or data that is reported in aggregate.
An “Identifiable” person is one who can be identified, directly or indirectly, in particular by reference to
an identification number or to one or more factors specific to his/her physical, physiological, mental,
economic, cultural or social identity.
“Controller” means a person or organization which, alone or jointly with others, determines the purposes
and means of the processing of Personal Data.
“Third-Party” and “Third-Parties” do not include third-parties that are acting as an Agent to perform
task(s) on behalf of and under the instructions of Allied Motion.
An “Agent” is a third-party acting as an agent to perform a task or tasks on behalf of and under the
instructions of Allied Motion.
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Approved:
Effective Date: XX/XX/XXXX
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President and CEO
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“Sensitive information” is Personal Information specifying medical or health conditions, racial or ethnic
origin, political opinions, religious or philosophical beliefs, trade union membership, membership in other
organizations, past or present, or information specifying the sexual orientation or preferences of the
individual.
Collection of Employee Data
In connection with your employment, Allied Motion may ask you to provide certain information only for
limited and specified purposes such as providing payroll, benefits and government required reporting,
including, but not limited to, your name, mailing address, telephone numbers, citizenship, country of
residence, country of origin, gender, birth date, marital status, name of dependents, birth date of
dependents, occupation of dependents and national identification number. Additionally, we may maintain
information relating to your employment with the Company including, but not limited to, your employee
identification number, business unit/division of employment, department, physical work location, job
code, compensation rate, supervisor, work shift, hire and termination date, appraisal dates and ratings,
training, skills, educational background, language proficiency, certifications and licenses.
Use of Employee Data Employee
Data collected by Allied Motion will be used for various administrative and record keeping purposes by
Allied Motion.
PRIVACY SHIELD PRINCIPLES
EU Personal Data is processed subject to the Privacy Shield Principles (the “Principles”).
NOTICE
Allied Motion informs individuals about the types of Personal Data collected and, where applicable, the
entities or subsidiaries of Allied Motion also adhering to these Principles. Allied Motion informs
individuals of the purposes for which it collects and uses information about them, the identities or types
of third-parties to which Allied Motion discloses the information, the purposes for which Allied Motion
may disclose and the choices and means Allied Motion offers individuals for limiting the use and
disclosure of such personal information.
This notice is provided in clear and conspicuous language when individuals are first asked to provide
personal information to Allied Motion or as soon thereafter as is practicable, but in any event before
Allied Motion uses such information for a purpose other than that for which it was originally collected or
processed by the transferring organization or discloses it for the first time to a Third-Party.
CHOICE
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Approved:
Effective Date: XX/XX/XXXX
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President and CEO
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Allied Motion offers individuals the opportunity to choose whether their personal information is: (a) to be
disclosed to a Third-Party; or (b) to be used for a purpose that is incompatible with the purpose(s) for
which it was originally collected or subsequently authorized by the individual. Allied Motion provides
individuals with clear and conspicuous, readily available, and affordable mechanisms to exercise these
choices. Employees should communicate with their Human Resources representative to express their
choice to withhold their Personal Data. Employees will be advised of the implications of withholding
their Personal Data such as lack of access to company provided benefits or services.
Allied Motion will not provide “choice” when disclosure is made to a third party that is acting as an agent
to perform task(s) on behalf of and under the instructions of Allied Motion. Allied Motion shall always
enter into a contract with such agent to protect the confidentiality and security of your personal data.
Allied Motion will obtain the express consent (opt in) from individuals if Sensitive Information is to be:
(a) disclosed to a third party; or (b) used for a purpose other than those for which it was originally
collected or subsequently authorized by the individuals through the exercise of opt-in choice. Allied
Motion will treat as sensitive any Personal Information received from a third party that identifies and
treats it as sensitive. Allied Motion will provide advanced notice to employees when Personal Data is to
be disclosed or used for a different purpose.
ACCOUNTABILITY FOR ONWARD TRANSFER
To transfer personal data to a third party acting as an agent, Allied Motion shall:
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Transfer such personal data only for the limited and specified purposes.
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Ascertain that the Agent is obligated to provide at least the same level of privacy protection as is
required by the Privacy Shield Principles.
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Take reasonable and appropriate steps to ensure that the Agent effectively processes the Personal
Information transferred in a manner consistent with Allied Motion’s obligations under the Privacy
Shield Principles.
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Require the Agent to notify Allied Motion if the Agent determines it can no longer meet its
obligation to provide the same level of protection as is required by the Privacy Shield Principles.
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Upon notice, take reasonable and appropriate steps to stop and remediate any unauthorized
processing or access.
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Provide a summary or representative copy of the relevant privacy provisions of its contract with
the Agent to the US Department of Commerce
When transferring Personal Data to a third party acting as a Controller, Allied Motion shall comply with
the Notice and Choice principles. Allied Motion shall also enter into a contract with the third-party
Controller. The contract shall provide that such data may only be processed for limited and specified
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Approved:
Effective Date: XX/XX/XXXX
_______
President and CEO
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purposes consistent with the consent provided by the individual. It will provide the same level of
protection as the Privacy Shield Principles. The contract will require the Controller to notify Allied
Motion if the Controller determines it can no longer meet this obligation. The contract shall provide that
when such a determination is made the third-party Controller shall cease processing or take other
reasonable and appropriate steps to remediate.
SECURITY
Allied Motion shall take reasonable and appropriate measures to protect Personal Data from loss, misuse
and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved
in the processing and the nature of the Personal Data.
DATA INTEGRITY AND PURPOSE LIMITATION
Allied Motion will only process Personal Information in a way that is compatible with the purposes for
which it has been collected or subsequently authorized by the individual. Allied Motion shall take
reasonable steps to ensure that Personal Data is accurate, complete, reliable for its intended use, and
current. Personal information shall be retained in a form identifying or making identifiable the individual
only for as long as it serves a purpose of processing consistent with the purpose for which it was collected
or subsequently authorized by the individual.
ACCESS
Allied Motion provides individuals with access to their Personal Data for purposes of correcting,
amending or deleting that information where it is inaccurate or has been processed in violation of the
Principles. Allied Motion, reserves the right to deny access where, in the reasonable opinion of Allied
Motion, the burden or expense of providing such access would be disproportionate to the risks to the
individual’s privacy or where the rights of persons other than the individual would be violated.
RECOURSE, ENFORCEMENT AND LIABILITY
Effective privacy protection includes robust mechanisms for assuring compliance with the Principles,
recourse for individuals who are affected by non-compliance with the Principles, and consequences when
the Principles are not followed.
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Enforcement - Allied Motion has procedures to verify the attestations and assertions it makes
about Allied Motion’s privacy practices are true and that privacy practices have been
implemented as presented. Allied Motion verifies compliance with the Principles through selfassessment or outside compliance reviews. Any employee that violates these Principles will be
subject to disciplinary procedures in accordance with Allied Motion’s disciplinary policy.
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Recourse - In compliance with the Principles, Allied Motion commits to resolve complaints
about its collection of Personal Information. Individuals who are affected by or witness non-
_____________________________________________________________________________________________
Approved:
Effective Date: XX/XX/XXXX
_______
President and CEO
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compliance with these Principles are encouraged to report the matter to their supervisor, Human
Resources or Allied Motion’s Whistleblower Hotline which may be done online at
www.ethicspoint.com or telephonically using the following toll-free number: Ethics Point: 1-855405-6559. Alternatively, individuals may contact the US Data Privacy Officer whose direct
contact information is:
Allied Motion Technologies
Attn: Colin Adams
495 Commerce Drive
Suite 3
Amherst, NY 14228
716-242-8634
[email protected]
Allied Motion will respond to a complaint within 45 days of receipt.
If a complaint cannot be resolved with Allied Motion directly, there are readily available
independent recourse mechanisms by which individual’s complaints and disputes can be
investigated and expeditiously resolved at no cost to the individual and by reference to the
Principles.
For complaints involving human resource Personal Data of EU citizens, Allied Motion commits
to cooperate with the panel established by the EU Data Protection Authorities and comply with
the advice given by the panel with regard to human resources data transferred from the EU in the
context of the employment relationship. Complaints regarding processing of HR Personal Data
pertaining to EU citizens may be reported by the individual to the relevant Data Protection
Authority.
This resource mechanism is available free of charge. The U.S. Department of Commerce agrees
to cooperate with the EU Data Protection Authority (DPA) to receive, review and undertake best
efforts to facilitate resolution of the of the complaint and respond to the DPA within 90 days.
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Liability - In the context of an onward transfer, Allied Motion has responsibility for the
processing of Personal Information it receives under the Privacy Shield and subsequently
transfers to a third party acting as an Agent on its behalf. Allied Motion shall remain liable under
the Principles if its Agent processes such Personal Information in a manner inconsistent with the
Principles unless Allied Motion can demonstrate that it is not responsible for the event giving rise
to the damage.
_____________________________________________________________________________________________
Approved:
Effective Date: XX/XX/XXXX
_______
President and CEO
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