ALOH NY Company, LLC (“ALOH NY”) respects individual privacy and values the confidence of its customers, employees, vendors,
consumers, business partners and others. ALOH NY strives to collect, store, process and distribute Personal information in a
manner consistent with the laws of the countries in which it does business and has a tradition of upholding the highest
ethical standards in its business practices. This Data Protection and Privacy Policy (the "Policy") sets forth the privacy
principles that ALOH NY follows with respect to Personal information transferred to ALOH NY from anywhere in the world.
I. SCOPE
This Policy applies to all Personal information received by ALOH NY in any format including electronic, paper or verbal. ALOH
NY collects, stores and processes Personal information concerning current and former employees, as well as applicants for
employment through its Internet websites, its intranet site, electronic mail and manually. ALOH NY will not sell or share
this information with third parties in ways different than what is disclosed in this Policy. On a global basis, ALOH NY will
establish and maintain business procedures that are consistent with this Policy.
ALOH NY collects, stores, and processes Personal information from current and past employees and applicants for employment,
such as name, contact information, government identifier, financial account information, and family information. This
information is maintained at the Corporate and Regional HQ level by ALOH NY and its authorized agents, depending on the
level of the position as well as the local office of the employee or applicant. ALOH NY collects Personal information for
employment related purposes and legitimate human resource business reasons such as personnel and job candidate
administration and assessment, recruitment and staffing; payroll administration; absence monitoring; training and
development; management planning; appraisal and promotion; union negotiation; production and publication of company
address books and telephone and e-mail directories; managing email and other communication systems; production of employee
Identity cards; monitoring the use of company resources; information to contact close relatives in case of emergency;
filling employment positions; administration and operations of its benefit and compensation programs; meeting governmental
reporting requirements; security, health and safety management; performance management; company network access;
facilitating workplace communications; workforce analytics, and authentication. ALOH NY does not request or gather
information regarding political opinions, religion, philosophy or sexual preference. To the extent ALOH NY maintains
information on trade union membership, medical health, race or ethnicity, ALOH NY will protect, secure and process that
information in a manner consistent with this Policy and applicable law.
ALOH NY also collects, stores, and processes Personal information from prospective customers, consumers, vendors,
professional advisers and consultants, distributors, dealers, suppliers business partners and others, such as name, contact
information, assist in the administration of employee benefit and compensation programs, and financial or other payment
information. This information may be maintained at its corporate offices in Great Neck, New York, or at other ALOH NY
facilities, and its authorized agents, consistent with local legislation. ALOH NY collects this Personal information for,
among other things, legitimate business reasons such as processing and fulfilling orders; customer service; the provision
of services or products to ALOH NY, product, warranty and claims administration; meeting governmental reporting and records
requirements; maintenance of accurate accounts payable and receivable records; marketing; internal marketing research;
safety and performance management; financial and sales data; and contact information. All Personal information collected by
ALOH NY will be used for legitimate business purposes consistent with this Policy.
ALOH NY may process and disclose Personal information to service providers, advisors, potential transactional partners, or
other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which an
ALOH NY business is acquired by or merged with another business, or sells, liquidates, or transfers all or a portion of its
assets.
ALOH NY also may process or disclose Personal information as is reasonably necessary or legally required on important
public interest grounds, to respond to lawful requests by public authorities (including to meet national security or law
enforcement requests), to meet governmental reporting or records requirements, or for the establishment, exercise or
defense of legal claims by ALOH NY or other companies within its corporate group.
II. DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that processes Personal information provided by ALOH NY to perform tasks on behalf of or at
the instruction of ALOH NY.
"ALOH NY" means ALOH NY, its subsidiaries, divisions and groups.
"Personal information" means any information or set of information that identifies or could be used by or on behalf of ALOH
NY to identify an individual. Personal information does not include information that is anonymized, or publicly available
information that has not been combined with non-public Personal information.
"Sensitive Personal information" means Personal information that reveals race, ethnic origin, trade union membership,
political opinions, or religious or philosophical beliefs, that concerns health or sex life, or that contains criminal
records. In addition, ALOH NY will treat as Sensitive Personal information any Personal information received from a third
party where that third party treats and identifies the Personal information as sensitive.
III. PRIVACY PRINCIPLES
ALOH NY commits to subject the Personal information covered by this policy to the following principles:
(1) NOTICE: Where ALOH NY collects Personal information directly from individuals, it will inform them about the purposes
for which it collects, stores and processes Personal information about them, the types of non-Agent third parties to which
ALOH NY discloses that information, and the choices and means, if any, ALOH NY offers individuals for limiting the use and
disclosure of their Personal information. Notice will be provided in clear and conspicuous language when individuals are
first asked to provide Personal information to ALOH NY, or as soon as practicable thereafter, and in any event before ALOH NY
uses the information for a purpose other than that for which it was originally collected.
(2) CHOICE: ALOH NY will offer individuals the opportunity to choose (opt-out) whether their Personal information is (a) to
be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally
collected or subsequently authorized by the individual.
For Sensitive Personal information, ALOH NY will give individuals the opportunity to affirmatively and explicitly consent
(opt-in) to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other
than the purpose for which it was originally collected or subsequently authorized by the individual.
ALOH NY will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.
(3) DATA INTEGRITY AND PURPOSE LIMITATION: ALOH NY will use Personal information only in ways that are compatible with the
purposes for which it was collected or subsequently authorized by the individual. ALOH NY will take reasonable steps to
ensure that Personal information is relevant to its intended use, accurate, complete and current.
(4) ACCESS AND CORRECTION: Upon request, ALOH NY will grant individuals reasonable access to Personal information that it
holds about them. In addition, ALOH NY will take reasonable steps to permit individuals to correct, amend or delete
information that is demonstrated to be inaccurate or incomplete. Any employees that desire to review or update their
Personal information can do so by contacting their local Human Resources Representative.
(5) SECURITY: ALOH NY will take reasonable precautions to protect Personal information in its possession from loss, misuse
and unauthorized access, disclosure, alteration and destruction. ALOH NY protects data in many ways. Physical security is
designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal information. Electronic
security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized
access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology.
ALOH NY limits access to Personal information and data to those persons in ALOH NY organization, or as Agents of ALOH NY, that
have a specific business purpose for maintaining and processing such Personal information and data. Individuals who have
been granted access to Personal information are aware of their responsibilities to protect the security, confidentiality
and integrity of that information and have been provided training and instruction on how to do so.
(6) RECOURSE, ENFORCEMENT AND LIABILITY: ALOH NY will conduct compliance audits of its relevant privacy practices to verify
compliance with this Policy and the relevant privacy principles. Any employee that ALOH NY determines is in violation of
this Policy will be subject to disciplinary action up to and including termination of employment.
IV. DISPUTE RESOLUTION
ALOH NY sees the Internet, intranets and the use of other technologies as valuable tools for communicating and interacting
with consumers, employees, vendors, business partners and others. ALOH NY recognizes the importance of maintaining the
privacy of Personal information collected through websites that it operates. ALOH NY' sole purpose for operating its websites
is to provide information concerning products and services to the public. In general, visitors can reach ALOH NY on the Web
without revealing any Personal information. Visitors on the Web may elect to voluntarily provide Personal information via
ALOH NY websites but are not required to do so. ALOH NY collects information from visitors to the websites who voluntarily
provide Personal information by filling out and submitting online questionnaires concerning feedback on the website,
requesting information on products or services, or seeking employment. The Personal information voluntarily provided by
website users is contact information limited to the user's name, home and/or business address, phone numbers and email
address. ALOH NY collects this information so it may answer questions and forward requested information. ALOH NY does not
sell this information.
ALOH NY may also collect anonymous information concerning website users through the use of "cookies" in order to provide
better customer service. "Cookies" are small files that websites place on users' computers to identify the user and enhance
the website experience. Company personnel periodically audit ALOH NY’ commercial websites to determine what cookies are used
on each. The cookies used are typically not intrusive and are not typically connected to visitors’ contact or other
identifiable information. Visitors may set their browsers to provide notice before they receive a cookie, giving the
opportunity to decide whether to accept the cookie. Visitors can also set their browsers to turn off cookies.
VII. CHANGES TO THIS POLICY
The practices described in this Policy are current Personal data protection policies as of March 2021. ALOH NY reserves the
right to modify or amend this Policy at any time consistent with the requirements of the relevant principles and
applicable law. Appropriate notice will be given concerning such amendments.