Privacy and Legal Notices

PRIVACY POLICY CONCERNING THE USE OF THE WEBSITE AND THE USE OF COOKIES

Armstrong International, Inc. (“Armstrong”) understands the importance of the privacy of its customers and the protection of their personal data. Armstrong hereby adopts this Privacy Policy (“Privacy Policy”) to explain how we collect, use, and transfer your personal and personally identifiable information when you use our websites or mobile applications, which may include, but are not limited to, armstronginternational.com, education.armstronginternationa.com, sage.com, and the SAGE mobile application (collectively the “Site”).

You understand and agree that Armstrong may store and process your personal and personally identifiable information on computers located outside of the UK or the European Union, including, but not limited to, in the United States. By using the Site, you agree to the collection and processing of your personal or personally identifiable information outside of the European Union.

Before using the Site or providing information to us, please carefully review this Privacy Policy. By using or accessing the Site, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Policy, as refused from time to time. Armstrong may modify, amend, replace, or suspend this Privacy Policy at any time. If you have questions or suggestions regarding our Privacy Policy, or if your personal information is not current, accurate, or complete, please contact us at:

Legal Department

Armstrong International, Inc.

816 Maple St.

Three Rivers, MI 49093

[email protected]

By providing Armstrong with your personal or personally identifiable information and using the Site, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within. Your jurisdiction, please do not use the Site and please do not provide any personal or personally identifiable information to Armstrong.

Scope

This Privacy Policy applies to all websites and mobile applications under the ownership or control of Armstrong. It is important for us that we create and maintain an environment where our visitors are having an enjoyable experience and where our customers feel comfortable that their information will not be misused.

To the extent possible, our policies and procedures are designed to comply with the applicable data protection laws, such as the General Data Protection Regulation 2016/679 (GDPR), the United Kingdom General Data Protection Regulation, and other national data protection laws.

What personal data is collected?

When you use the Site, we may collect personal or personally identifiable information from you (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could be linked, directly or indirectly, with a particular individual. It does not include anonymized data.

For the purposes as mentioned hereafter, Armstrong may gather and process the following categories of PII from you:

Communication Data. Communication data includes any communication that you may send to us through the Site, e-mail or social media. This may include your name, address, e-mail address, or social media account information.

Technical Data. Technical data includes data about your use of the Site, such as your IP address, your login data, your phone number, your mobile device model, your operating system, your geolocation, or your time zone. Armstrong may collect this data from your use of the Site or from advertising IDs or pixel tags, such as Google Analytics or Facebook tracking pixels.

User Data. User data includes data about how you use the Site and any data that you post to or authorize through the Site. This includes data stored in persistent cookies when you login to the Site and analytics data that is collected when you use the Site. User data may include your company and industry segment.

Marketing Data. Marketing data includes data about your preferences in receiving and interacting with Armstrong’s advertisements or content on the Site. Armstrong collects this data from your use of the Site and, in some instances, from advertising programs, such as Google Advertising IDs and Apple Advertising IDs.

Personally Sensitive Data. Personally sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, union membership, or information about your health. Armstrong does not collect or use personally sensitive data through the Site.

Armstrong may also collect publicly accessible information or other third party information in order to verify information we have collected and to manage and expand our business.

Why do we collect this information?

Armstrong collects the above-mentioned PII to understand your needs and to provide you with a better service, and more specifically we collect your PII for the following purposes:

To communicate with you, to respond to your (online) queries about our products or services, to provide you with information on our products, to record logs of our communication, to store information to respond to legal claims, and to follow-up with you concerning online offers;
To operate the Site, to authenticate you as a user of the Site, to ensure that timely and relevant content is provided to you, to secure the Site, to ensure that the Site operates in a fast and efficient manner, and to maintain backups of the Site;
To provide you with the products or services you have ordered;
To analyze your use of the Site, to route Site traffic, to administer and secure the Site, to provide location-relevant content, and to troubleshoot problems with the Site;
To improve our products and services;
To provide advertisements, including remarketing advertisements, to you;
To investigate complaints about the products or services or regarding our Site;
To comply with legal, regulatory and compliance obligations and requirements;
To send newsletters and / or promotional e-mails periodically about our products and services and about special offers or other information which we think that might be interesting for you;
To contacting you for market research purposes from time to time, whether by email or phone; and
To process your personal data for specific purposes as mentioned on specific forms as published on our Site on written notices or via e-mail.

How do we collect PII from third parties?

Armstrong may collect PII from you through third-party cookies and other technologies. This helps Armstrong understand how you use the Site and to understand any patters that may be associated with your use of the Site. This aids Armstrong in developing or improving its Site in response to your needs or wants.

Armstrong may use session or persistent cookies, which are more thoroughly discussed below. Armstrong may use the following third-party analytics providers, and you are directed to review their cookie policies:

Google Ads: https://policies.google.com/technologies/ads

Facebook Ads: https://www.facebook.com/policy/cookies/

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Salesforce: https://www.salesforce.com/company/privacy/

Twitter: https://twitter.com/en/privacy

AppNexus/Xandr: https://www.xandr.com/privacy/platform-privacy-policy/

HotJar: https://www.hotjar.com/legal/policies/privacy/

SiteScout: https://www.sitescout.io/privacy_policy

Armstrong may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, or Apple. These third parties may be based outside of the European Union.

How will your PII be transferred or shared?

Armstrong may share your PII:

With companies in our group and/or our affiliates;
With Armstrong’s authorized Sales Representative in your territory, who is permitted to use the information only for the purpose of selling Armstrong products and services to you, as well as for normal customer service purposes;
With Armstrong’s service providers, which provide Armstrong with information technology or other administrative services;
With any third party you have asked us to share your personal data with – such as any social media site if you have asked us to connect with your account;
With Armstrong’s accountants, auditors, insurers, or attorneys;
With law enforcement agencies, upon the receipt of a subpoena or court order or where necessary to protect Armstrong’s personnel or property; and
With government bodies that require Armstrong to report its processing activities.

When we share your PII, based on our legitimate interests, to third party providers who help us with our products and services, these third party providers will have access to your PII only when strictly necessary to perform their functions and they may not use that data for any other purpose.

Your PII will not be sold or rented to third parties.

In the event that the business of Armstrong is sold or integrated with another business, your PII will be disclosed to any prospective purchaser’s advisers and will be transferred to the new owners of the business. In this case, we will implement the appropriate safeguards to ensure the integrity, security, and confidentiality of your PII and your PII will be subject to the same level of respect for the protection of PII as Armstrong provides under this Privacy Policy.

Transfer of your personal data

Armstrong utilizes several applications that may transfer your PII to third party providers who are located in countries outside the European Economic Area (EEA). These applications include:

3rd Party Provider	Location	GDPR compliance	Purpose of app that stores Personal Data
Armstrong International datacenter	Three Rivers, MI USA	In process	Armstrong CRM Application Armstrong ERP Application Armstrong Website authentication
Google	Mountainview CA – USA	In Process	Web Analytics service
HotJar	Sleiman, Malta	Yes	Web Analytics service
HR Connect/Salesforce	San Francisco, CA USA	Yes	HRMS
Classroom Revolution	Baldwinsville NY – USA	In Process	Hosting services for Armstrong University Learning Portal
SAGE	Cincinnati OH – USA	NIST 800-171 GDPR Pending	Productivity application for utilities

This data transfer outside the EEA is legitimate if the recipient of the data is located in a country which provides an adequate level of protection following a European Commission adequacy decision. Some of these countries may not have equivalent data protection legislation to protection the use of your PII. In this case, we have assessed whether appropriate safeguards as within the EU are possible by, for example, executing standard contractual clauses. In particular cases, we will endeavor to obtain your preliminary consent for transferring your PII outside the EEA. For more information regarding the transfer of information you can follow the procedure as described in Article 7 below ( on the ‘Rights of the Data Subjects’).

How we use cookies

Some features of this Site are designed to give you a better online experience on our Site and will only work if we use cookies. We also use cookies to collect information about your online preferences. Cookies are text files which contain small pieces of information, sent by a web server to a web browser which allows the server to uniquely identify the browser on each page. They will be stored on your computer, tablet or phone when you visit a website.

Cookies may contain identifying information. Cookies enable us to gain information about the use of its websites. This information may be analyzed by third parties on our behalf.

a. We use the following categories of cookies on our Site:

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the Site and use its features. Without these cookies, services you have asked for, such as remembering your login details or shopping basket items cannot be provided.

Performance Cookies

These cookies collect anonymous information on how people use our Site. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation, shopping experience and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.

Functionality Cookies

These cookies remember choices you make such as the country you visit our Site from, language and search parameters such as size, color, or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

Targeting cookies or advertising cookies

For example, we use third party companies to provide you with more personalized advertisements when visiting other websites.

Social Media Cookies

These cookies allow you to share what you’ve been doing on the Site on social media such as Facebook. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work.

Google Analytics

We also use third party services such as Google Analytics to collect information about visitors to our Site. This information is aggregated to determine number of visits, average time spent, pages viewed, etc. We use this information to measure site usage, as well as to improve the content and value of our site. More information about the way Google processes your information is here –https://privacy.google.com/intl/en/index.html#. If you wish to disable Google Analytics on your browser, please follow https://tools.google.com/dlpage/gaoptout?hl=en.

b. Deletion of cookies and more information about cookies

Some cookies are deleted when you close down your browser (session cookies). Others remain on your device until they expire or you delete them from your cache (persistent cookies or tracking code) and enable us to remember things about you as a returning visitor.

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. The help option on the toolbar of most browsers will also tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please bear in mind that some personalized services may not be available if you choose to disable cookies.

Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.

To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioral advertising and online privacy.

Responding to Do Not Track Signals

You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. Our Site is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.

Rights of Data Subjects

You are entitled to see the PII held about you and to obtain a copy of the PII we hold. If your PII has been changed, you are entitled to ask us to rectify or complete or erase the outdated, incorrect, or incomplete PII we have about you. Furthermore you have the right to restrict the processing of your PII and to object to the processing of your PII. You have also the right to receive your PII, which has been provided to a controller, in a structured, commonly used, and machine-readable format, and you have the right to transmit such PII to another controller.

If you have opted to receive commercial e-mails, newsletters, or other communications from Armstrong at the time you registered on the Site, you may opt-out whenever you have changed your mind.

We may require you to provide verification of your identity to ensure that you have a legitimate right to make the request and to verify that we provide the answer to the person that has the legitimate right to send us one of the above-mentioned requests and to obtain the information.

Please note that in certain circumstances as provided by law we may withhold access to your information or that we may not grant your request where we have the right to do so under applicable data protection legislation.

If you wish to obtain more information regarding the processing of your personal data or if you wish to exercise your rights, please contact us at [email protected] or by postal mail at: Armstrong International, Inc 816 Maple Street, Three Rivers, MI 49093 USA – Attention Webmaster.

You have the right to lodge a complaint with the competent supervisory (data protection) authority.

Security

Armstrong is committed to trying to make sure that your PII is secure. We have implemented reasonable technical and organizational measures to secure your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed. You should, however, remember that the internet is an open system and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your PII for improper purposes.

This Site may contain links to third party websites. Armstrong is not responsible for the content of these websites and is not responsible for the privacy standards and practices of any third parties. We recommend that you read and understand the relevant privacy policies of these third parties and their websites before you accept their cookies and visit their website to ensure yourself that your PII is sufficiently protected.

Nevada Residents

If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may send us an email to [email protected] with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.

Children’s Privacy

We do not direct the Site to anyone under the age of 13 and we do not knowingly collect PII from anyone under the age of 13. If you are a parent or guardian of an individual under the age of 13 and believe that we may have collected PII from your child, please contact us at [email protected].

California Privacy Rights

The following rules apply solely to visitors and users of the Site who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, Armstrong collected the following categories of PII (A, B, D, and F) as defined in the California Consumer Privacy Act within the last twelve months. Armstrong’s uses of this PII are detailed above in this Privacy Policy:

Category	Examples	Collected
A. Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	YES
B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e))	Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.	YES
D. Commercial	Records of products purchased.	YES
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES

Armstrong obtains these categories of PII directly from California residents when they complete forms through our Site or provide it to us as a part of a transaction or inquiry concerning our products. Armstrong also obtains these categories of PII indirectly from California residents while observing their actions on our Site and from third parties or service providers that they have authorized to receive and share PII.

California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you.

California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information” or “Do Not Sell My Info.” By selecting this link or icon, you “Opt Out,” which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.

To submit a request for a list of the categories of PII collected from you or to request that Armstrong delete your PII, please email us at [email protected] or send a letter to us at the following address:

Legal Department

Armstrong International, Inc.

816 Maple St.

Three Rivers, MI 49093

To verify your request, we may request certain information from you to confirm that you are an Armstrong user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to Armstrong to disclose or delete your personal information. To do so, you must provide Armstrong with proof that the individual or business has been appointed as your agent, such by providing a signed power of attorney form, and provide accurate responses to any information requested by Armstrong that may be necessary to confirm that you are an Armstrong user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by Armstrong for their exercise of these rights conferred under California law.

Important Legal Notice

TERMS GOVERNING YOUR USE OF THE ARMSTRONG INTERNATIONAL, INC. SITE

Please note that your use of the Armstrong International, Inc. (“Armstrong”) website (the “Site”) is governed by these terms and conditions (“Terms of Use”) which you should read carefully before using the Site. By using the Site, you indicate your agreement to be bound by these Terms of Use, which are governed by the laws of the State of Michigan, U.S.A. The laws of the State of Michigan U.S.A. shall apply in any dispute between you and Armstrong without regard to principles of conflict of laws. You agree that any legal proceedings arising out of these Terms of Use or your use of the Site (including online purchases), may be brought only in the courts of the State of Michigan, U.S.A., or the United States District court for the Western District of Michigan, and you consent to the jurisdiction of these courts, which shall have exclusive jurisdiction. If you do not agree with all of these Terms of Use, do not use this Site.

Armstrong grants you a limited license to access and make use of this site, and in so doing, copies thereof may be created on our computer, but only for your internal business purposes not otherwise prohibited by these Terms of Use. You may not retain copies of the Site for any other purpose, nor may you use any Armstrong trademark, trade dress, logo, trade name or other intellectual property for any purpose that is prohibited by, or contrary to, these Terms of Use or applicable law.

All content on this Site, such as text, graphics, logos, button icons, images, audio clips, digital downloads, data compilations and software, is the property of Armstrong or its content suppliers and is protected by the U.S. and international copyright laws. This Site contains and uses intellectual property that is owned by, or licensed to Armstrong, and which shall remain the intellectual property of Armstrong and/or its licensors. Without limiting the generality of the foregoing, “ARMSTRONG,” “ARMSTRONG INTERNATIONAL,” “ARMSTRONG SERVICE” and other trademarks, trade names, graphics, logos, page headers, button icons, scripts, product names and numbers, and service names are trademarks, registered trademarks, or trade dress of Armstrong in the U.S. and/or other countries. Armstrong’s trademarks and trade dress may not be used in connection with any product or service that is not Armstrong’s, in any manner that is likely to cause confusion among customers, or in any manner that disparages or discredits Armstrong.

Armstrong does not warrant that the content of this Site (including product and service information) is accurate, complete, reliable, current or error-free. The data, information and training materials found on this Site and in the Armstrong literature referenced herein are provided for general information purposes and should not be relied upon for solving specific problems or applications. There may be other factors and aspects of your system or application that have not been considered in the materials presented at this Site. For these reasons, you should consult an Armstrong Sales Representative or a professional engineer to carefully study and make specific recommendations for your specific situation. Armstrong accepts no liability or responsibility arising from your use of this Site or any content available therein, including, without limitation, any direct or indirect or consequential loss, loss of profits, loss of business, wasted costs or loss of opportunity or any other losses or damages regardless of whether they arise at law, in statute, by tort or otherwise caused by your viewing of the Site or arising out of any information or material on it. Nothing herein is intended to cancel, modify or supersede Armstrong’s Limited Warranty and Remedy terms, which shall apply in all sales of Armstrong products, including any online purchases. Click here to view Armstrong’s limited Warranty and Remedy terms. Without limiting the generality of the foregoing, Armstrong specifically disclaims any and all implied warranties with regard to your use of the Site, including, without limitation, any implied warranty of merchantability, or fitness for a particular purpose.

When you register as a user of this Site, you agree to provide true, accurate, up to date and complete information (“User Data”) as required by the registration form(s) made available to you via the Site. Armstrong may rely upon your User Data to supply you with information about its products and services, or otherwise to identify and/or contact you. If your User Data is inaccurate, misleading, out of date or incomplete, Armstrong may terminate your use of the Site immediately or suspend your account and all current and future use of the Site (or any part of it). Without limiting the generality of the foregoing, you may not use a false e-mail address, impersonate any person or entity, or mislead as to the origin or ownership of a credit card. In addition, you agree to indemnify Armstrong for any damages, losses or liabilities caused by inaccurate, misleading, out of date or incomplete information provided by you.

Armstrong recognizes the importance of maintaining the privacy of personal and business data. Click here to view Armstrong’s Privacy Policy for the Site.

The performance and quality of the Site depends in part upon the level of service of third party providers and Armstrong does not give any warranties or undertakings as to performance or quality in regard to such providers. However, please notify us of any concerns or problems you experience and we will use our reasonable efforts to rectify the matter. You may contact us at [email protected]. In addition, Armstrong makes no warranties and shall have no liability regarding the products, performance, services, information, representations or website content of any third parties that provide links to this Site.

You are advised that some of the products shown on the Site may not be available in certain markets. Local regulations may restrict the use of the products shown below the conditions quoted. In the interests of development and improvement of products, Armstrong reserves the right to change product specifications from time to time without notice.

THE FOLLOWING ACCEPTABLE USE POLICY APPLIES TO ALL USES OF THE SITE: As a User, you may not:

Use the Site in any way to send unsolicited commercial email or “spam”, political campaign material, chain letters, materials known to contain a virus, or conduct any similar abuse of the Site;
Publish, post, distribute or disseminate material that is fraudulent, defamatory, infringing of intellectual property rights, obscene, indecent or other material that is unlawful, harmful to third parties, or inappropriate material via the Site;
Use the Site to threaten, harass, stalk, abuse, disrupt or otherwise violate the rights (including rights of privacy and publicity) of others;
Engage in fraudulent, illegal or unlawful activities through the Site;
Make available or upload any data, script or compiled program files of any sort to the Site except as expressly authorized herein;
Obtain or attempt to obtain access, through whatever means, to areas of Armstrong’s network or the Site that are identified as restricted or confidential; or
Transfer material to or from your computer that infringes any laws, regulations or the rights of others.

You are responsible for maintaining the confidentiality of your account and password and for restricting access to your computer, and you agree to accept responsibility for all activities that occur under your account or password. You are responsible for the content of your emails, or any other material distributed via or through the Site. You agree to indemnify Armstrong for any costs, expenses or liabilities it incurs due to your use of the Site or any use of the Site under your password or account.

Armstrong reserves the right to remove any information or material it deems to be in breach of any of these terms and conditions without warning and/or to make available such information when required to do so by law or when requested to regulatory bodies or law enforcement organizations having jurisdiction.

Armstrong may update or amend these Terms of Use at any time or introduce different or additional terms and conditions for specific services, as Armstrong deems appropriate in its sole discretion. Armstrong may communicate any such changes to you via the Site. Please note that you may be able to access the Site from anywhere in the world. These Terms of Use apply to you regardless of how you have accessed the Site and regardless of the location in which you conduct business. You agree that these Terms of Use are legally binding on you to the fullest extent allowed by applicable law. If any of these Terms of Use shall be deemed invalid, void, or for any reason unenforceable, that portion shall be deemed severable and shall not affect the validity and enforceability of any remaining terms or conditions.