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EU Privacy Policy for Connect with Crown

This Privacy Policy explains how we process your personal data when you use the Connect with Crown reporting system. Connect with Crown is a confidential reporting system that allows you to report Crown business related incidents and ask questions in regard to accounting practices, internal accounting controls, auditing matters, bribery, banking, financial concerns, customs / trade or competition laws, data privacy, discrimination or harassment, quality / regulatory or manufacturing standards, environmental protection / health and safety laws, or unsafe working conditions. Use of Connect with Crown is voluntary. You should provide information that is, to your knowledge, correct and concrete. Crown has a strict anti-retaliation policy for reports made in good faith

  1. Controller and Data Protection Officer

    2. The controller for processing your data is the regional Crown entity to which the reported facts relate.

    For European Union (EU): You can find a list of EU Crown entities that offer Connect with Crown at the end of this Privacy Policy. You can contact our European Data Protection Officer at the aforementioned address or at this e-mail address: EU-DataProtection@crown.com.

  2. What personal data do we process and for what purposes?

    3. If you submit a report through Connect with Crown, you will be asked to provide a description of any questionable conduct, including all relevant details such as the name and title of all individuals involved. The processing of the data is based on our legitimate interest (for EU Art. 6 para. 1 sentence 1 lit. f GDPR) in learning about incidents and questionable behavior, conducting investigations and preventing such incidents and behavior in the future.

    If you choose not to remain anonymous, but to provide your name and contact information, we process this data based on your consent (for EU Art. 6 para. sentence 1 lit. a GDPR).

    This Connect with Crown website uses session ID cookies in order to make it easier to navigate the site and retain preferences and information during your use of the website. A session ID cookie expires when your browser is closed. If you reject session ID cookies, accessibility of the website may be limited.

  3. What data do we share, with whom and why?

    4. (a) The data will be received and compiled by our service provider NAVEX/EthicsPoint and processed by a central office of the Crown Group. For controllers in the European Union, NAVEX/EthicsPoint and any other service provider we use is bound by a data processing agreement in which we require them to comply with the strict data protection requirements of the European Union, to only process personal data for the services requested by us or in accordance with our instructions, and to keep such data confidential.

    (b) If the data refer to another Crown company or its employees, we may transfer the data to the respective company. If the data refer to another Crown entity in the EU, we may also transfer the data to the European Compliance officer. Transfer of data for this purpose is based on the legitimate interest of ourselves and other Crown entities in informing the respective entities and, if applicable, the European compliance officer of questionable conduct or other reported issues (for EU Art. 6 para. 1 sentence 1 lit. f GDPR) to enable them to conduct investigations and prevent incidents and misbehavior in the future.

    (c) We may be legally required to provide information to the reported person. This may include, inter alia, the fact that a report has been filed, the reported information and the identity of the reporting person, if known. Transfer of data for this purpose is necessary for compliance with a legal obligation (for EU Art. 6 para. 1 sentence 1 lit. c GDPR).

    (d) If the data contain information about criminal acts or reportable circumstances or in case of legal requirements or official or court orders, we may disclose the data to the competent authority. Transfer of data for this purpose is necessary for compliance with a legal obligation (for EU Art. 6 para. 1 sentence 1 lit. c GDPR) or based on our legitimate interest (for EU Art. 6 para. 1 sentence 1 lit. f GDPR) in conducting official investigations or the like.

    (e) When we send your personal data from the European Economic Area (EEA) to countries outside the EEA, which lack an adequate level of data protection, we first take reasonable measures to ensure that your personal data are fully protected at all times, e.g. through adoption of the standard data protection clauses issued by the European Commission. You can receive a copy of the suitable, adequate guarantees we have obtained here, upon request: EU-DataProtection@crown.com.

  4. What rights do I have as a user?

    5. As an EU user of the system, you can exercise your rights at any time in accordance with the relevant provisions of law (Arts. 7 Sec. 3, 15-18, 20-21, 77 GDPR) by using the aforementioned contact data. Under the conditions established in the regulation, you have the right:

    • to obtain information regarding the personal data that we store about you,
    • to demand rectification of inaccurate data or completion of incomplete data,
    • to demand erasure or restriction of personal data concerning you,
    • to have the data you provided, which we are processing based on your consent or in the performance of a contract, disclosed to you or a third party in a commonly used, machine-readable format. To the extent that you request the direct transfer of the data to another controller, this will be done to the extent technically feasible,
    • to withdraw your consent to data processing at any time. The lawfulness of the data processing performed prior to your withdrawal of consent shall remain unaffected, and data may already have been revealed to other persons, such as our compliance officer or due to privacy law to the person about whom you are reporting; if you want to withdraw your consent, we therefore advise you to declare your withdrawal at the earliest possible time, at the latest within one month after your report submission as we may be obliged to inform the person about whom you are reporting within that period,
    • to lodge complaints with a supervisory authority
      • To the extent that your personal data are processed based on our legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f) GDPR, you have the right to object to the processing of your personal data in accordance with Article 21 GDPR to the extent that there are grounds for this relating to your particular situation. If you wish to make use of your right to object, it is sufficient to send an e-mail to withdraw@crown.com.
    • To assert your rights, simply send an e-mail to EU-DataProtection@crown.com or use the other contact data provided above.
  5. Duration of data storage

    6. The personal data you submit will generally be held for a period of sixty days after the completion of any investigation relating to your report and will then be erased if no statutory retention periods or other statutory grounds for further retention exist. Other grounds for additional retention can, for example, be the public interest or the establishment, exercise or defense of legal claims.

  6. Updating this Policy

    7. This Privacy Policy may be updated from time to time. You can inform yourself of the latest changes at any time.

    Last update: July 2019

  7. List of EU Crown entities

    8. Crown Gabelstapler GmbH & Co. KG
    Philipp-Hauck-Strasse 12
    85622 Feldkirchen, Germany
    Tel: (0049) 89 93 0020

    Crown Lift Trucks S.L.
    C/ Sierra de Guadarrama, 94
    28830 San Fernando de Henares (Madrid), Spain
    Tel: (0034) 902 732 252

    Crown Lift Trucks S.r.l.
    Via Antonio Pacinotti 28
    Cinisello Balsamo (MI) 20092, Italia
    Tel: (0039) 02 99 19971

    Crown Lift Trucks Ltd.
    Rutherford Road
    Basingstoke, Hampshire, RG24 8PD, United Kingdom
    Tel: (0044) 845 850 92 76

    Crown Handling NV
    Satenrozen 12
    2550 Kontich, Belgium
    Tel: (0032) 3 450 71 71

    Crown Intern Transport BV
    Damsluisweg 75
    1332 EB Almere, Netherlands
    Tel: (0031) 36 549 41 80

Declaration of Consent

Please be aware that the provision of personal data referring to yourself is completely voluntary. If you provide personal data about yourself, such as your name, contact details, job details etc., you are giving your consent to its processing.

You may withdraw your consent at any time, however the lawfulness of the data processing performed prior to your withdrawal of consent shall remain unaffected and data may already have been revealed to other persons, such as our compliance officer or due to privacy law to the person about whom you are reporting. If you want to stay anonymous, please do not provide any personal data relating to you.