Curtiss-Wright Corporation (“Curtiss-Wright”, “our”, “us”, “we”), is the Data Controller of the personal information we collect and process that we need to manage our business and meet our legal and contractual obligations.
Your privacy is important to us. This privacy notice describes to those individuals that interact, communicate, or otherwise engage with Curtiss-Wright, including our subsidiaries and affiliates, how and why Curtiss-Wright collects, uses and protects your personal data and the associated individual rights you have in relation to your personal data.
When we interact with you, we may also provide you with additional privacy statements about specific processing activities or offer you additional choices about how Curtiss-Wright processes your personal information.
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WHO WE ARE
The Curtiss-Wright Corporation registered address is: 130 Harbour Place Drive, Suite 300, Davidson, NC 28036, U.S.A
Penny & Giles Controls Limited, a company registered in England and Wales under number 00843903, whose registered address is 15 Enterprise Way, Aviation Park West, Bournemouth International Airport, Christchurch, Dorset, BH23 6HH, United Kingdom, represents Curtiss-Wright Corporation in Europe.
PRINCIPLES FOR PROCESSING PERSONAL DATA
As the data controller, Curtiss-Wright is accountable to you and to the supervisory authorities for how we process your personal data. Curtiss-Wright will ensure that personal data will be:
- Processed lawfully, fairly and in a transparent manner.
- Collected for specified, explicit and legitimate purposes and not processed further in ways incompatible with those purposes.
- Adequate, relevant to and limited to what is necessary. For example, we will not hold more information than is required for the specific purpose.
- Accurate and where necessary, kept up to date. Every reasonable step will be taken to ensure the personal data we hold is correct and not misleading as to any matter of fact.
- Not kept for longer than we need it. Curtiss-Wright operates to standard data retention periods that wherever possible, comply with documentation requirements.
- Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction, or damage.
- Processed in consideration of the requirements of accountability and the above-mentioned principles of data processing, using appropriate technical or organisational measures.
PERSONAL INFORMATION WE COLLECT
- Information you give us. Curtiss-Wright collects personal data in a variety of ways. When you interact with us directly or indirectly via our third-party service providers, we may ask you for personal information to provide a service or carry out a transaction that you have requested. For example, we collect data via the job application process where we require forms to be completed, CVs or resumes and your passport or other government issued identity documents are often required to fulfil the requirements of a site visit. You may also provide personal information to us when you correspond with us, through either interview, meetings or some other assessment or it could be something like an enquiry, some feedback or even a customer support request. The personal information collected directly from you may also include:
- Identity data, such as your name, title, company/organization name, e-mail address, telephone and fax numbers and physical address (including street, city, state, postal code, and/or country).
- Registration data, such as information provided by you when you interact with our employees via email, post, or over the phone, when you register for an account to use one of our websites, including usernames and passwords or when you are registered for a site visit.
- Recruitment data, including information submitted in connection with a job application or other inquiry.
- Marketing and communications data, including your marketing preferences and your subscriptions to our publications.
- Business development data, when you or your employer become(s) a business associate, a supply chain provider or a representative or distributor or when we have face to face meetings with you.
- Financial information, including credit card or other financial account information for the purpose of enabling us to facilitate your purchase of Curtiss-Wright products and services that may be available on our websites.
- Due diligence, information provided by you will assist us in complying with our legitimate due diligence processes, including identity verification, fraud prevention, criminal activity or restricted party screening and other such legal and professional obligations.
- Export control information, such as your nationality, citizenship and country of residence or any other personal information that allows us to assess risk of diversion of controlled products or data to a destination subject to an embargo or other trade controls and to determine your eligibility under export control regulations to receive information about certain technologies.
- Transaction data, including inquiries about and orders for our products and services and details of payments to and from you, or when you place an order or sign a contract with us, either on your own behalf, or on behalf of your employer.
- Event registration information, including information you provide when filling in e-registration forms.
- Physical access data, relating to details of your visits to our premises.
- Special categories of data. In certain circumstances we may be required to collect special category (sensitive) personal information from you. For example, in connection with the registration for and provision of access to an event or seminar, we may ask for information about your health for the purpose of identifying and being considerate of any disabilities or special dietary requirements you may have. We will always ensure appropriate security measures (e.g., physical security devices, encryption, and access restrictions) are taken depending on the nature of the data and the risks associated with the intended uses.
- Social Media information. The privacy policies, statements and guidance published by social media networks apply to your use of Curtiss-Wright social media networks. We encourage you to read the privacy policies and guidance published on each social media network you use. If you are connecting to our website through a Curtiss-Wright social network, we do not collect any personal information in accordance with your privacy settings on each social network.
- Third Party Websites. Our websites may contain links to and from the websites of our partner networks, advertisers, and affiliates. These third-party websites have their own privacy policies that we do not accept any responsibility or liability for.
- Closed Circuit Television (CCTV). In certain locations, Curtiss-Wright will process your personally identifiable images via CCTV surveillance systems for the prevention and detection of crime, to protect and safeguard our staff and visitors and to fulfil our obligations to health and safety legislation.
- Your feedback, including feedback from you about our websites as well as our products and services generally.
- Each time you use one of our websites, we may automatically collect technical information, including the Internet protocol (IP) address used to connect your computer or device to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.
- Some of the information about you that we collect relates to usage data. For example, how you use our websites, what pages you view, the number of bytes transferred, the links you click and the materials you access. We may record the date and time you access the site, the website from which you linked to one of our sites, your geographical location when accessing the website and any phone number used to call the contact phone number provided on our website and other actions taken within the sites.
- In some cases, Curtiss-Wright collects personal data about you from third parties, such as references supplied by former employers, personal contacts, or information from background check providers. In circumstances as permitted by law, we receive personal information from credit reference agencies, criminal records and disclosed barring services and restricted party screening agencies.
- Children/Minors Data. Curtiss-Wright websites are not directed to, and should not be used by, children or minors under the age of 16 and we do not knowingly process personal information from such individuals. If you are a minor as understood by the laws of your country of residence you should not submit personal information through our websites.
WHY WE PROCESS YOUR PERSONAL INFORMATION
Curtiss-Wright processes your personal data for legitimate business purposes, such as:
- Business contact information. Curtiss-Wright will collect and use business contact information to engage in communications or transactions, including for conducting due diligence regarding, or providing or receiving, a product or service. For example, we may collect and use this business contact information to facilitate and manage orders, contracts, warranties, maintenance, and similar business functions, for credit analysis and collection purposes, to assist with our own internal compliance and legal requirements, and (if necessary) to defend our interests and claims.
- Human resource information. To support the Curtiss-Wright Human Resource functional area about recruitment and talent acquisition, you may provide us with information about yourself, such as a resume, curriculum vitae, professional references, information about education and job background and information about professional training and certifications. We may use this information for the purpose of employment consideration, background checks and employment eligibility. We may use a third party (e.g., job recruiter) or social media platform to solicit, collect and process employment applications.
- Marketing. As part of our marketing strategy and in accordance with applicable laws and regulations, we will provide you with service or product information you request from us and send you marketing information about our products and services. We will collect data about your online activities and identify your interests so that we can provide advertising that is most relevant to you. We will invite you to trade events and otherwise communicate with you about special offers, news items, surveys, special offers and related topics.
- Sales. We may use your personal information to deliver services to you or carry out transactions you have requested, including, but not limited to, providing information on Curtiss-Wright products or services you have purchased or otherwise use, registering purchased products, processing product orders, handling warranty claims, replacing product manuals, answering customer service requests, and facilitating the use of our Sites.
- Technical Administration. We may use your personal information to help protect and improve our networks and systems in line with Curtiss-Wright Information Technology policies and guidelines, including ensuring our websites operate effectively, technical administration, maintenance and support, troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Security. We may use your personal information to support Curtiss-Wright Security programmes that maintain physical security of and control access to our facilities, offices, equipment, and information.
- Health & Safety. We may use your personal information to support our obligations to national and international health and safety law, in obtaining occupational health advice, by ensuring Curtiss-Wright complies with obligations to individuals with disabilities.
- Enforcement. We may use your personal information to help us detect, prevent, and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse.
THE LAWFUL BASIS ON WHICH WE RELY TO PROCESS YOUR PERSONAL INFORMATION
Curtiss-Wright will process your personal information for lawful reasons only. As required by law, we will ensure there is a lawful basis for the processing of your personal information.
- Where the processing is necessary for the performance of a contractual arrangement with you, we will process your personal data under the lawful basis of CONTRACT. For example, we need to process your personal data to pay you in accordance with the requirements of any contract you may have with us, either on your own behalf, or on behalf of your employer.
- Where the processing is necessary to comply with our legal obligations, such as compliance with applicable law, regulations, or court orders, we will process your personal data under the lawful basis of LEGAL OBLIGATION. For example, we often must process personal information with organisations such as tax authorities, credit reference agencies, criminal records and disclosed barring services and restricted party screening agencies.
- Where the processing is necessary to meet our legitimate business interests and there is a compelling justification for the processing and the processing is conducted in a way that is reasonably expected with minimal impact to an individual’s privacy rights, we will process your personal data under the lawful basis of LEGITIMATE INTEREST.
- Where the processing is necessary to obtain an individual’s consent to process their data, we will process your personal data under the lawful basis of CONSENT. We ensure that any consent is obtained via a clear affirmative act establishing a freely given, specific, informed and unambiguous indication of the individual’s agreement to the processing of their personal data (i.e. a positive opt-in). When the processing has multiple purposes, consent will be obtained for each of them. EXPLICIT CONSENT will be obtained using very clear and specific statements and any request for consent to process will be prominent and separate from our terms and conditions. Individuals can withdraw consent at any time and refuse to offer consent without detriment.
SHARING YOUR PERSONAL DATA
Curtiss-Wright will not sell or swap your information with any third party. In accordance with applicable law, and only when such disclosure is necessary to enable our service providers to deliver the contracted services, Curtiss-Wright will share your personal information with third parties as defined below:
- Curtiss-Wright Corporation. We are required to share your personal information with other members of our group, which means our subsidiaries and group companies, as reasonably necessary for the legitimate business purposes set out in this Privacy Notice.
- Legal Obligation. We are required by law to disclose or share your personal information to comply with a legal obligation. For example, we are required to provide relevant personal information to tax authorities or other legally mandated activity such as criminal investigations, court proceedings, the protection of your rights, the health and safety of our employees, customers, vendors, and visitors.
- Service Providers. Curtiss-Wright will share your personal information with approved third-party providers that we have contracted with to provide confidential services on our behalf. For example, website hosting, customer relationship management, recruitment processes, visitor management, customer and vendor due diligence, financial transaction management, restricted party screening, information technology services.
- Distributors and other trusted business partners. Curtiss-Wright will share your personal information with distributors and other trusted business partners that distribute our products and other services to you.
- Business Transactions. Curtiss-Wright will disclose your personal information to global financial institutions, government entities and shipping companies or postal services involved in fulfilment of our business transactions.
- Mergers and Acquisitions. In certain circumstances, Curtiss-Wright will sell, buy, divest, merge or otherwise reorganize our organisation. To do this, we will disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, divestiture, or sale of a business asset.
PROTECTING YOUR PERSONAL DATA
Curtiss-Wright takes the security of your personal information seriously. We use technical and organisational measures to provide a level of security appropriate to the risk of processing your personal information. These measures prevent your personal information from being accidentally lost, accessed, altered, used or disclosed in an unauthorised way. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.
- International transfers. Curtiss-Wright is a US global organization, and your personal information may be transferred to, held, stored, or used across various locations worldwide such as, but not limited to, the US, UK, European Union, Costa Rica, Canada, Mexico, China and India. This means that when we collect your personal information it may be processed in countries that may have data protection laws that are different to the laws of your country.
- We transfer personal data from the UK, EU, and Switzerland to other countries, some of which have not been determined by the UK, EU, and Switzerland authorities to have an adequate level of data protection. For example, their laws may not guarantee you the same privacy rights or they may not be capable of addressing your complaints.
- When we engage in such transfers, we use mandated legal mechanisms, such as the European Commission standard contractual clauses or the UK International Data Transfer Agreement to help protect your rights and enable these protections to travel with your data.
- Technical and organisational measures. All Curtiss-Wright affiliates and third-party agencies are required to comply with the provisions of this Privacy Notice and will implement contractual or other safeguarding measures to ensure an adequate level of protection to protect your rights to privacy and your personal information, appropriate to the laws of your country of residence. These measures mandate a duty of confidentiality and an obligation to implement appropriate technical and organisational measures to ensure the security of your personal data.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
STORING YOUR INFORMATION
Your personal information will be stored on systems and in facilities owned or operated by Curtiss-Wright or those of our approved third-party suppliers. It may be stored on systems and in facilities located both within and outside the EEA. Your data may be stored on systems and in facilities located within countries approved by the EU and the UK and on servers located within countries not approved by the EU and the UK. Within Curtiss-Wright, your information will be stored on our secured systems.
- Retention of your personal data. Curtiss-Wright policy is to retain only those records that are required for the effective running of our businesses and to meet our obligations to the individuals whose personal information we process. Curtiss-Wright will retain your personal data in accordance with legal and regulatory requirements. This means we will retain your personal data for no longer than is necessary for the purposes for which we are processing it.
- As soon as the personal information is no longer necessary for the purpose for which it was originally collected, it will be either anonymized (where permitted by applicable law), deleted or destroyed.
YOUR INDIVIDUAL DATA SUBJECT RIGHTS
National and international data protection law governs our processing of your personal data and you may have certain rights in relation to your personal data. You may have the right to:
- Be informed about the collection and use of your personal data. You have received this information within this Privacy Notice.
- Access your personal information. Allows you to obtain a copy of your personal information as well as other supplementary information (this largely corresponds to the information we have already provided in this privacy notice). It helps you understand how and why we are using your data and to check we are doing it lawfully.
- Request deletion or destruction of your personal information in certain circumstances. For example, if (i) it is no longer necessary for us to process your personal information for the purposes for which it was originally collected or (ii) you withdraw your consent to our processing, where consent is the only legal basis on which we rely to process your personal information or (iii) your personal information has been unlawfully processed or (iv) it is necessary for us to erase your personal information for compliance with applicable law.
- Correct inaccurate personal data or update it if required. It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
- Object to the processing of your personal information or ask us to restrict or suppress processing of your personal information that is likely to cause, or is causing you, damage or distress.
- Request portability of your personal information. Data portability allows you to obtain and reuse your personal data for your own purposes across different I.T. services, perhaps with different organisations.
- Stop your data being used for direct marketing purposes. This is an absolute right.
- Not have a decision made about you that is based solely on automated decision-making or profiling, and to understand the logic involved in any such decision-making or profiling, if that decision produces legal effects about you or significantly affects you.
You also have the right to complain to a Supervisory Authority responsible for overseeing compliance with data protection law in your jurisdiction about our collection and use of your personal information if you believe our processing of your personal information does not comply with data protection law.
More detailed information relating to national data privacy, including how to contact your relevant supervisory authority is available here: Global Privacy Laws. If you need further guidance, please contact the Curtiss-Wright Data Protection Officer DPO@curtisswright.com. Curtiss-Wright would however appreciate the chance to address your concerns, so please feel free to contact us regarding any complaint you may have. We will not discriminate against individuals for exercising their data privacy rights.
You should be aware that not all your data subjects’ rights are absolute and will apply in certain circumstances only. Curtiss-Wright will facilitate your exercise of the rights that apply to you in accordance with applicable law. However, even if your personal information is not afforded protection under, or otherwise subject to, a data protection law, we may seek to accommodate any request or inquiry you may have regarding our data processing activities. If you have questions about your rights or wish to exercise your rights, you can contact us using the contact information at the end of this Privacy Notice.
CALIFORNIA CONSUMER PRIVACY ACT
The California Consumer Privacy Act (CCPA) became effective on January 1st, 2020 and it created several rights for California residents. A California resident is a natural person (as opposed to a corporation or other business entity) who resides in California, even if the person is temporarily outside of the state.
If you are a resident of California, we process your personal information in accordance with the CCPA. Under the CCPA, personal information is defined as information that identifies, relates to, or could reasonably be linked with you or your household. It does not include publicly available information that is from federal, state, or local government records
The information contained in this section is required by the CCPA and supplements, and is supplemented by, this Privacy Notice.
- Principles. Curtiss-Wright will ensure that personal information will be processed in accordance with the principles for processing personal information. Please see section Principles For Processing Personal Data.
- Personal Information Processing. You have the right to know what personal information we are collecting, how we obtain this data, what our business purposes are for that collection and who we share the data with:
- Sale. We do not sell your personal data, so we do not offer an opt-out to the sale of personal data.
- Rights. You have certain rights in relation to the processing of your personal information. You have the right to:
- Know the categories of personal information we collect.
- Know the specific pieces of personal information we collect.
- Know the categories of sources from which we collected personal information.
- Know the purposes for which we use your personal information.
- Know the categories of third parties with whom we share your personal information.
- Know the categories of information that we sell or disclose to third parties.
- Request that we delete your personal information.
You should be aware that not all rights are absolute and may apply in certain circumstances only. In accordance with applicable law and processes that may require identity verification, Curtiss-Wright will provide you the information you request for the 12-month period preceding your request, free of charge and within 30-days.
- Disclosure of Subject Access Requests. The CCPA requires us to disclose the number of requests received, complied with, in whole or in part, or denied. Subject Access Requests to access personal information as described above, are processed within 30 days.
- During 2021, Curtiss-Wright received no subject access requests.
- Non-Discrimination. The CCPA prohibits discrimination in the exercise of your rights. Discrimination may include denial of goods or services or providing a different level or quality of service or charging different prices. Should you wish to exercise your rights, you will not be discriminated against.
- However, if you refuse to provide your personal information to Curtiss-Wright or ask us to delete it and the personal information is necessary for us to provide you with goods or services, we may not be able to complete that transaction.
You may make these requests yourself or use an authorised agent. If you have questions about your rights or wish to exercise your rights, you, or your agent, can contact us using the contact information at the end of this Privacy Notice.
- Security. Curtiss-Wright takes the security of your personal information seriously. Please see the section Protecting Your Personal Data
- Complaints. You also have the right to complain to the California Office of the Attorney General, who are responsible for overseeing compliance with CCPA, about our collection and use of your personal information, if you believe our processing of your personal information does not comply with the CCPA.
If you believe Curtiss-Wright has violated the CCPA, you may file a Consumer Complaint with the Office of the Attorney General. If you choose to file a complaint, you will need to explain exactly how Curtiss-Wright violated the CCPA and describe when and how the violation occurred.
Curtiss-Wright would however appreciate the chance to address your concerns, so please feel free to contact us regarding any complaint you may have. We will not discriminate against individuals for exercising their data privacy rights.
CHANGES TO THIS PRIVACY NOTICE
As a minimum, we will review and update this Privacy Notice every 12 months. When we do, we will revise the “last updated” date at the top of the Privacy Notice and take such additional steps as may be required by law. Please check for updates from time to time so you are always fully aware of what personal information is collected by us, and how it is used.
If you have any questions or concerns about our use of your personal information, please contact the Curtiss-Wright Data Protection Officer:
- By Post
Data Protection Officer
15 Enterprise Way, Aviation Park West, Bournemouth Airport, Christchurch, BH23 6HH, UK.
- By Email
- By Telephone
+44 (0) 1202 034000