Essex Brownell

Privacy Statement

STATEMENT AND PURPOSE

Applicable Laws impose a number of obligations with respect to the Processing of Personal Data. Superior Essex Group respects individual privacy and is committed to comply with the legal standards imposed by

Applicable Laws in our business practices involving the Processing of Personal Data. We are accountable for and committed to comply with the key data protection principles and core requirements set out in Applicable Laws.

This Policy describes the key data protection principles we follow and reflects our approach with respect to the respect for the privacy of individuals and the protection of Personal Data.
SCOPE

This Policy applies to all Superior Essex Group establishments in the EU, as well as all other Superior Essex Group establishments to the extent they receive any Personal Data from the EU, or are otherwise subject to the Applicable Laws.

The Personal Data shall be Processed in accordance with this Policy and Applicable Laws.

This Policy should be read in conjunction with Superior Essex Group’s other policies as listed in Section XIII of this Policy. Superior Essex Group may implement additional policies, procedures or practices as may be required to comply with this Policy or with Applicable Laws.

Data Protection is the shared responsibility of all Superior Essex Group employees and business units and all employees and business units are expected to be familiar with and adhere to the principles and requirements set forth in this Policy.
DEFINITIONS

In addition to the words defined elsewhere in this Policy, the following words used herein have the meanings set forth below:

“Affiliate” means any entity, which is partially or wholly controlled by, controls or is in common control with the respective entity.
“Applicable Laws” means the GDPR and any national laws implementing the GDPR in the EEA countries.
“Automated Decision-Making” means the process of making a decision based solely on automated Processing, including Profiling, of Personal Data, which produces legal effects concerning a Data Subject.
“Controller” means any natural or legal person, public authority, agency or other body, which, alone or jointly with others, determines the purpose(s) and means of the Processing of Personal Data.
“Data Subject” means identified or identifiable natural person to whom the Personal Data relates. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“EEA” means the European Economic Area, which includes all EU Member States as well as Iceland, Liechtenstein and Norway.
“Effective Date” means May 25, 2018.
“Employees” means full-time employees, part-time employees, temporary employees, reinstated employees, rehired employees and retired and former employees, interns and trainees.
“Establishment” implies the effective and real exercise of activity through stable arrangements; the legal form of such arrangements, whether through a branch or a subsidiary with legal personality, is irrelevant.
“EU” means the European Union.
“GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
“Personal Data” means any information relating to a Data Subject. Personal Data includes Special Categories of Personal Data.
“Policy” means this General Privacy Policy.
“Privacy Officer” means the person designated under Section XII below.
“Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Personal Data Breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise Processed by an entity’s systems.
“Special Categories Personal Data” includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data Processed for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
“Superior Essex Group”, “we”, “our”, “us” means Superior Essex Inc., a Delaware corporation, registered at Corporation Service Company, 251 Little Falls Drive, Wilmington, DE 19808, Essex Group, Inc., a Michigan corporation, registered at CSC-Lawyers Incorporating Service (Company), 601 Abbot Road, East Lansing, MI 48823, Superior Essex International LP, a Delaware limited partnership, registered at Corporation Service Company, 251 Little Falls Drive, Wilmington, DE 19808, and their respective Affiliates.

KEY DATA PROTECTION PRINCIPLES
When Processing Personal Data, we will apply the following key data protection principles:
- We will Process the Personal Data lawfully, fairly and in a transparent manner in relation to the Data Subject (hereinafter, the “Lawfulness, Fairness and Transparency Principle”);
- We will only collect the Personal Data for specified, explicit and legitimate purpose(s) and we will not further Process them in a manner that is incompatible with those purposes (hereinafter, the “Purpose Limitation Principle”);
- We will ensure that Personal Data are adequate, relevant and limited to what is necessary in relation to the purpose(s) for which they are Processed (hereinafter, the “Data Minimization Principle”);
- We will ensure that the Personal Data are accurate and, where necessary, kept up to date and that every reasonable step is taken to ensure that Personal Data that are inaccurate, having regard to the purposes for which they are Processed, are erased or rectified without delay (hereinafter, the “Accuracy Principle”);
- We will not keep the Personal Data in a form that permits identification of Data Subjects for longer than necessary for the purpose(s) for which the Personal Data are Processed (hereinafter, the “Storage Limitation Principle”);
- We will Process the Personal Data in line with the Data Subjects’ rights (hereinafter, the “Data Subjects’ Rights”); and
- We will ensure that appropriate technical, organizational and security measures are put in place to protect the Personal Data when Processed, including protection against unauthorized or unlawful Processing and against accidental loss, destruction or damage (hereinafter, the “Integrity, Confidentiality and Security Principle”).
The Purpose Limitation Principle

In the course of our business, we collect and Process different types of Personal Data from different categories of Data Subjects for a variety of purposes. We will identify specific, explicit and legitimate purposes in advance and we will document them in our Records of Processing Activities (see Section VIII). We will inform the Data Subjects of these purposes when we first collect the Personal Data or as soon as possible thereafter (see the next sub-section B), unless a relevant exception applies.

We will not Process Personal Data that had been collected for a specific purpose, for a different incompatible purpose, unless permitted by Applicable Laws.

If you intend to Process Personal Data for a different purpose than the one initially identified, please speak to the Privacy Officer prior to commencing the Processing activity.
The Lawfulness, Fairness and Transparency Principle

1. Lawfulness and Fairness
Processing of Personal Data is only lawful if it is permitted by Applicable Laws.

We will only Process Personal Data based on one of the permissible legal grounds listed in the Applicable Laws. The legal grounds for Personal Data Processing we most typically rely upon include, but are not limited to the following:
- The necessity to perform a contract to which the Data Subject is party;
- The necessity to comply with an EU-originated legal obligation to which we are subject;
- The necessity for the purposes of legitimate interests pursued by us as a Controller or by a third party; and/or
- The consent given by the Data Subjects.
We aim to minimize the amount of Special Categories of Personal Data that we Process. We will only Process Special Categories of Personal Data, if permissible under Applicable Laws, for example, when we are legally obliged to do so or with the explicit consent of the Data Subjects.

We will identify the appropriate legal basis in advance and document them in our Records of Processing Activities (see Section VIII below).
Transparency

In accordance with Applicable Laws, before we Process the Personal Data, we will provide a so-called data protection notice to the individuals in which we describe, at a minimum, in a manner easy to understand for the addressees, the following:
- The identity and contact details of Superior Essex Group entity/ies, which is/are the relevant Controller(s);
- The categories of Personal Data we Process;
- The purposes for which we Process the Personal Data and legal bases to do so;
- To whom we disclose the Personal Data;
- Whether we transfer the Personal Data outside of the EEA (including the country of destination and the transfer mechanisms used);
- The period for which we store the Personal Data (or, if that is not possible, criteria we used to determine that period);
- The rights Data Subjects can exercise with respect to the Processing of their Personal Data;
- Whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether the Data Subjects are obliged to provide the Personal Data and of the possible consequences of failure to provide such data; and
- The existence of Automated Decision-Making, including Profiling and in cases required by the GDPR, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such Processing for the Data Subject.
The Data Minimization Principle

We will implement reasonable technical and organizational measures to ensure that any Personal Data we Process are adequate, relevant and limited to what is necessary for the purpose(s) for which we Process them.
The Accuracy Principle

We will implement reasonable technical and organizational measures to ensure that any Personal Data we Process are accurate and kept up-to-date. We will check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
The Storage Limitation Principle

We will implement reasonable technical and organizational measures so we do not keep Personal Data longer than necessary for the purpose(s) for which they were collected or as otherwise required or permitted by Applicable Laws and in accordance with Superior Essex Group Records Retention Policy. We take all reasonable steps to securely destroy, or erase from our systems and records, all Personal Data that are no longer required.
The Data Subjects’ Rights

We respect the rights afforded to Data Subjects under Applicable Laws, in particular:
- Right of

Suggested Products

Suggestions

Categories

Suggested Products

Suggestions

Categories

Privacy Statement