Notice of Personal Information Processing

Thank you for choosing HDD Broker, Inc. ("HDD Broker") for your equipment brokerage needs. This notice is to inform you about the ways HDD Broker processes the Personal Information of its customers and the rights you have over that information.

Identity and Contact Information: HDD Broker is a Canada-based corporation with principal place of business at 110-3212 Jacklin Rd, Victoria, BC V9B 0J5. If you have questions or concerns about HDD Broker's privacy practices, please contact us at privacy@au.hddbroker.com. This will put you in touch with HDD Broker’s team and EU-based representative.

Personal Information Defined: This Notice concerns the processing of Personal Information. Personal Information is any information that identifies, or, in combination with other information, can be used to identify a natural person. As used in this Notice, Personal Information is the same as Personal Data, as defined by Regulation (EU) 2016/679 ("GDPR").

Purposes of Processing: HDD Broker processes its customers' Personal Information to support several purposes. The first category of purposes concerns Facilitating Transactions and Providing Services. If you purchase merchandise through HDD Broker or request our services, we will use your Personal Information to facilitate the transaction or fulfill the request, as well as to facilitate other services or purposes as you may request from us or our affiliates, such as merchandise delivery, maintenance, warranty service, financing, leasing, or credit services. These purposes of processing are generally necessary for us to fulfill our contractual obligations to you.

We also share our customers' information with our parent company and affiliates to serve our legitimate interests in coordinating efforts related to, e.g., provision of services, marketing, corporate strategy, and so on. Our parent company and affiliates may use your Personal Information consistently with the terms of their privacy policies. For example, these uses may include monitoring and managing the health of equipment manufactured by those entities and purchased using HDD Broker, delivering upgrades and product improvement communications, gauging your satisfaction with your equipment and communicating with you about your concerns, questions, and interests, making diagnoses and repairs, ensuring product safety, and carrying out recalls. Using your Personal Information to carry out support services that relate to your safety and the safety of persons using your equipment is necessary to the protection of your vital interests and the vital interests of others. Using your Personal Information for other support services is generally necessary for purposes of our parent company's and our affiliates’ legitimate interests in ensuring that they meet the needs and desires of their customers, respond to their concerns, and help to make sure their equipment stays up to date and in good working order.

HDD Broker also uses customers' Personal Information for marketing purposes as detailed in its privacy policy. These purposes are necessary for HDD Broker’s legitimate interests in marketing to its customers and strengthening its customer base.

Finally, HDD Broker uses customers' Personal Information to facilitate the making and receipt of payments, both of which are necessary for performance of contract obligations; to conduct credit bureau reporting, which is necessary for compliance with legal obligations; to analyze market share data points, which is necessary for purposes of HDD Broker's legitimate interests in better understanding the nature and state of its business and in developing corporate strategy; and to ensure security and prevent fraud, which is necessary for purposes of HDD Broker's legitimate interests in protecting itself and its customers from a variety of risks to their privacy and other interests.

Recipients of Your Personal Information: In order to fulfill the purposes set out above, certain parties may receive your Personal Information from us. The recipients of your Personal Information include departments internal to HDD Broker and its parent company, affiliated companies, and business partners. We may also share your Personal Information with third-party service providers, collections agencies, and public authorities.

Cross-Border Transfers: Your Personal Information may be subject to cross-border transfers. In particular, your Personal Information may be transferred to HDD Broker Headquarters in Canada, to our parent company's headquarters in the USA, or to our affiliates and/or their authorized dealers worldwide. The European Commission ("EC") has issued an adequacy decision concerning transfers of Personal Information to the United States from the European Union, adopted July 12, 2016, which provides for the lawful transfer of Personal Information from the European Union to the United States so long as such transfers take place within the EU-US Privacy Shield Framework. HDD Broker's parent company is in the process of self-certifying under that framework. The EC has also issued an adequacy decision concerning transfers of Personal Information to commercial organizations in Canada from the European Union, adopted December 20, 2001.

Data Retention: HDD Broker keeps different kinds of Personal Information for different lengths of time, depending on the purposes for which it is processed and the unique circumstances of your situation. However, the following are criteria that HDD Broker will use to make that determination: The existence and nature of any legal requirements to which HDD Broker is subject concerning data retention; the nature of the relationship between you and HDD Broker; the existence of any contracts between you and HDD Broker and/or the existence of financing arrangements; and the necessity, as determined by HDD Broker and its parent company, of the Personal Information to support current or future safety campaigns, recalls, litigation or alternative dispute resolution, or other legal work. In every case, HDD Broker will keep your Personal Information as long as necessary to fulfill the purposes of processing as set forth in its privacy policy.

Your Rights: The GDPR, Articles 15 to 21, grants data subjects a number of different rights over the way their Personal Information is processed. The following is intended to help you understand those rights.

Right to Access: This allows you to request information about your Personal Information, including what data HDD Broker has and how and why it is being processed.

Right to Rectification: In the event that some or all of the Personal Information that HDD Broker has concerning you is inaccurate, this gives you the right to have those inaccuracies rectified.

The Right to Erasure: In some cases, you may have the right to request that HDD Broker erases any and all of your Personal Information that it has in its possession.

Right to Restriction of Processing: This gives you the right to request, in some circumstances, to have HDD Broker process your Personal Information only with your consent.

Right to Object to Processing: This right is in bold because it is particularly important. Where HDD Broker is processing your Personal Information on the ground of its legitimate interests, or to carry out tasks in the public interest or to exercise official authority, you have a right to object to the processing on grounds relating to your particular situation. In cases where you object to HDD Broker’s processing of your Personal Information for direct marketing purposes, the processing will cease.

Right to Data Portability: This allows you to request from HDD Broker a copy of your Personal Information which it has on file and to transfer that information to someone else without interference from HDD Broker. In some cases, you may be able to request that HDD Broker transfer your Personal Information directly to a third party on your behalf.

Should you wish to exercise these rights, you may reach out using the contact information above for assistance.

Withdrawal of Consent: To the extent that HDD Broker processes any of your Personal Information on the basis of your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing that was based on your consent before its withdrawal.

Disclosure of Ownership and Information Sharing: HDD Broker, Inc. is wholly owned by its parent company, Vermeer Corporation ("Vermeer"). Vermeer's headquarters are located in the United States of America at 1210 Vermeer Road East, Pella, Iowa 50219. HDD Broker and Vermeer jointly control and share certain data, which may include Personal Information. This arrangement is carried out for, and consistently with, the Purposes set out above. In addition, HDD Broker and Vermeer have agreed to cooperate with one another in the event of a breach of personal data in order to mitigate the risk posed to data subjects, as well as in order to carry out requests concerning the exercise of data subject rights, described above. For more information about Vermeer's data privacy practices, please consult Vermeer's Privacy Policy, which is made available online at https://www.vermeer.com/EM/en/N/privacy. You may also contact Vermeer's Senior Data Strategy Manager by sending an e-mail to privacy@au.hddbroker.com.

Making a Complaint: If you are a natural person in the EU and at any time you believe that HDD Broker has violated one of your rights listed above, or if you believe HDD Broker is in violation of one or more of the provisions of the GDPR, you have the right to lodge a complaint with a Data Protection Authority. More information about Data Protection Authorities is available online at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en.

Automated Decision-Making: HDD Broker does not envision that the Personal Information you provide will be subject either to profiling or automated decision-making.

Last Updated: June 28, 2018