Privacy Policy

PB Swiss Tools US Trading Inc. (PB Swiss Tools, we or us) is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully. If you are a California resident, please review Section 17, entitled “Your California Privacy Rights.”

By submitting personal information to PB Swiss Tools or its service providers and agents and by accessing our website at https://pbswisstools.us (“Website”), you agree that we may collect, use and disclose such personal information in accordance with this privacy notice and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting us. If you refuse or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you.

PLEASE REVIEW THIS PRIVACY NOTICE BEFORE USING THIS WEBSITE OR CREATING ANY USER ACCOUNT IN CONNECTION THEREWITH. IF YOU DO NOT AGREE WITH THIS PRIVACY NOTICE, DO NOT USE THE WEBSITE NOR CREATE ANY USER ACCOUNT. THIS PRIVACY NOTICE GOVERNS THE USE OF THIS WEBSITE AND APPLIES TO ANY PERSONAL INFORMATION YOU MAY SUBMIT TO THIS WEBSITE. BY SUBMITTING ANY PERSONAL INFORMATION TO THIS WEBSITE, YOU AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY NOTICE.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

1. INFORMATION ABOUT US

2. WHAT PERSONAL INFORMATION DO WE COLLECT AND FOR WHAT PURPOSES?

3. MARKETING

4. WEBSITE INFORMATION

5. CONTENT

6. EMPLOYEE INFORMATION

7. PROTECTION OF CHILDREN’S PERSONAL DATA

8. LEGAL CLAIMS

9. INFORMATION WE RECEIVE FROM THIRD PARTIES

10. SPECIAL CATEGORIES OF DATA

11. WHY ELSE DO WE USE YOUR INFORMATION?

12. SHARING YOUR INFORMATION

13. WHERE WE STORE YOUR INFORMATION

14. DATA SECURITY

15. HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

16. YOUR RIGHTS

17. YOUR CALIFORNIA PRIVACY RIGHTS

18. CHANGES TO THIS PRIVACY NOTICE

1. INFORMATION ABOUT US

1. INFORMATION ABOUT US

1.1 PB Swiss Tools US Trading Inc., 150 North Michigan Avenue, 35th floor, 60601 Chicago, Illinois, is the controller of data/information processing for this website according to EU privacy laws. For all (mobile) applications that refer to this privacy notice, PB Swiss Tools is the controller of the data processing. PB Swiss Tools is committed to take all responsibility for the protection and security of your personal information/data.

1.2 If you have any questions, our contact details are:

1.2.1 PB Swiss Tools US Trading Inc., 150 North Michigan Avenue, 35th floor, 60601 Chicago, Illinois

1.2.2 Contact our Consumer Services

1.2.3 Or you can call Consumer Services at 1-312-561-9798

2. WHAT PERSONAL INFORMATION DO WE COLLECT AND FOR WHAT PURPOSES?

2. WHAT PERSONAL INFORMATION DO WE COLLECT AND FOR WHAT PURPOSES?

2.1 Personal information means any information about an individual from which that person can be identified. It does not include personal information where all references to the identity of the relevant individual have been removed (anonymous personal information).

2.2 We may collect, use, store and transfer different kinds of personal information about you. Those kinds of personal information can be categorized as follows:

Identity Personal information includes: first name and last name.

Contact Personal information includes email, address, phone number and phone call records.

Financial Personal information includes: any payment information.

Transaction Personal information includes details about payments to you (refunds) and purchase of products.

Commercial information includes: your purchasing history and tendencies.

Technical Personal information includes internet protocol (IP) address and geolocation information, cookies, and other technology on the devices you use to access this website.

Internet activity information includes browsing history, search history, interactions with our website and online advertisements, and user-generated/submitted content.

Marketing and Communications Personal information includes Inferences we make about you based on the above information to predict your characteristics and preferences.

2.3 We have set out below, in a table format, a summary of the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purposes for which we will use your personal information.

2.4 Correspondence or interaction (for example by email, telephone, post, SMS, social media, or via our website) between you and us, may include personal information (such as Identity Personal Information and Contact Personal Information) in that correspondence. This may include enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organization.

We will keep and use that information to carry out our contract with you (if applicable), to comply with any legal requirements for us to maintain certain records or carry out certain verifications, and/or for our legitimate interests in dealing with a complaint or enquiry and administering your (or your organisation’s) account or order and any services we offer, as well as to review and improve our offerings, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

3. MARKETING

3.1 We may use your Identity Personal Information and Contact Personal Information in order to send you information about our products and services which you might be interested in. We may collect such information directly from you, or through a third party or service provider.

3.2 You always have the right to “opt out” of receiving our marketing materials. You can exercise the right at any time by contacting us. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials, you will be added to our suppression list to ensure we do not accidentally send you further marketing.

3.3 If you are an existing customer, we use your contact details as necessary to maintain our existing business relationship with you and may send you marketing information that promotes our products and services (including by electronic communications) unless you request to opt out of receiving such latter electronic communications.

3.4 If you are not an existing customer and are not acting in a professional capacity as part of a company or LLP, we will only contact you for marketing purposes with your consent (whether we have collected your details directly from you, or through a third party or service provider).

3.5 We never share your Personal Information with third parties for marketing purposes unless we have your “opt-in” consent to share your details with a specific third party or service provider for them to send you marketing. We do use third parties or service providers to send out our marketing, but we only allow them to use that information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

3.6 We retain your details on our marketing list until you “opt-out” at which point we add you to our suppression list. We keep that suppression list indefinitely to comply with our legal obligations to ensure we don’t accidentally send you any more marketing.

3.7 When we send marketing emails to you, we use “web beacons” to collect information about when you open the email, your IP address and browser or email client type, and other similar information. We do this as necessary for our legitimate interests in reviewing and considering our direct marketing activities. We keep this information to send you relevant and personalized content, to improve your global experience and to adjust the quantity of communications we send you.

3.8 We may use any of type of personal information as described in subsection 2.2 to tailor our marketing materials to your needs and interests. To achieve this objective, we may share your personal information with third parties or service providers for the purposes of website, marketing, and advertising analytics.

4. WEBSITE INFORMATION

4.1 We may collect information about you and your use of our website via technical means such as cookies, webpage counters and other analytics tools. This may include your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We use this as necessary for our legitimate interests in administering and improving our website and its content, to ensure it operates

effectively and securely, and to develop our business and inform our marketing strategy. We may also create aggregate statistical data from that information (for instance, overall numbers of website visitors) which is not personal information about you.

4.2 We, or other advertisers, may also use this information to serve advertisements to you. Where those adverts are targeted, this may involve using website information and information we (or our advertisers working on our behalf) have obtained from other entities. This won’t include information such as your name or contact details. Where our adverts are displayed to you using your information, your information is used as necessary for our legitimate interests in marketing to you.

4.3 We keep this website information about you for a maximum of 24 months from when it is collected, or the relevant cookie expires.

4.4 Our website may, from time to time, contain links to other websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow other entities to collect or share data about you. We do not control these other websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

5. CONTENT

5.1 This is information about you which you provide when you post content on our website. This may include reviews, photographs, videos, and other content which you post on our website.

5.2 We may display and publish this information on our platforms as part of our contract with you or as necessary for our legitimate interests in providing content to our users in accordance with our Terms of Use.

5.3 This information is kept for as long as you have an account with us and may be retained and displayed indefinitely after you close your account.

6. EMPLOYEE INFORMATION

6. EMPLOYEE INFORMATION

If you work for one of our customers, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you or provided by your organization. Your organization should have informed you that your information would be provided to us and directed you to this Notice. We use this as necessary for our legitimate interests in managing our relationship with your organization. If we have a

business relationship with you or your organization, we may receive information about you from your organization.

7. PROTECTION OF CHILDREN’S PERSONAL DATA

7.1 The protection of children's personal data is extremely important. PB Swiss Tools understands that it has a responsibility to protect the privacy of children and has no intention of collecting the data of children under the age of 13.

7.2 This website and other PB Swiss Tools online properties are directed to, and meant to be used by, adults. We do not knowingly collect any information from persons under the age of 13. If we have reason to believe that a child under the age of 13 has attempted to submit a registration application, this will be rejected with the notification that applications from children under the age of 13 are not accepted. If we become aware that we have collected any personal information from a child under 13, we will delete that information. We ask parents and other guardians to check on and monitor their children's Internet usage in order to protect them.

8. LEGAL CLAIMS

Where we consider there to be a risk that we may need to defend or bring legal claims or other actions that we might take to protect our rights or legal interests, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.

9. INFORMATION WE RECEIVE FROM THIRD PARTIES

9.1 We may also receive information about you from the following sources:

9.1.1 Our service providers and third parties. We work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies) who may provide us with information about you, to be used as set out above.

9.1.2 Businesses we have bought. If we have acquired another business, or substantially all of its assets, which originally held your information, we will hold and use the information you provided to them, or which they otherwise held about you, in accordance with this privacy notice, to the extent that our use of your personal information is consistent with the purpose for which it was originally collected.

9.1.3 Our other channels. This is information we receive about you if you use any of the other websites we operate or the other services or products we provide. In this case we will have informed you and received your consent when we collected that data if we intend to share those data internally and combine it with data collected on this website. We will also have told you for what purpose we will share and combine your data.

10. SPECIAL CATEGORIES OF DATA

We do not collect any “special categories” of more sensitive personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, as well as information about criminal convictions and offences).

11. WHY ELSE DO WE USE YOUR INFORMATION?

11.1 Common uses of your information. We will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this privacy notice because:

11.1.1 we need to perform a contract we have entered into with you.

11.1.2 where permitted by law, it is necessary for our legitimate interests (or those of another entity) and your interests and rights do not override those interests;

11.1.3 we need to comply with a legal obligation; or

11.1.4 we need to protect your interests (or someone else’s interests) or where it is needed in the public interest (although these circumstances are likely to be rare).

11.2 Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

12. SHARING YOUR INFORMATION

As well as any sharing listed above, we may also share your information with third parties, service providers and affiliated companies in the PB Swiss Tools.

These entities are required to respect the security of your personal information and to treat it in accordance with the law and in a manner consistent with this privacy notice.

12.1 Why might we share your personal information with other entities?

We may share your personal information with other entities if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We may also share your personal information with suppliers, merchants and retailers who require such information for the purpose of payment processing, order fulfillment, local delivery (for example when we fulfil your custom product order) or enabling us to properly carry out our business such that we can serve you best.

12.2 Which third parties or service providers process your personal information?

In addition to the third-party merchants and retailers with whom we may share your information for the purpose of order fulfilment and local delivery, we also may need to share your personal information with third-party service providers (including contractors and designated agents) so that they can carry out their services. Such third party service providers include our payment processor, Moneris; our local sales tax identifier, Avalara; our shipping and delivery carrier, ShipBob; our social media API supplier, Full Contact; our email/sms marketing service provider, Klaviyo; our website analytics solution provider, Google Analytics; our online advertising service providers, Facebook, Bing, Google and Snapchat ads; our fraud detection service provider, Signifyd; and our ecommerce platform, Shopify who use the data in order to fulfil your order and provide a more personalized and relevant experience.

12.3 When might we share your personal information with affiliated companies?

We may share your personal information with affiliated companies in the PB Swiss Tools as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, and for system maintenance support and hosting of data.

12.4 How secure is your information with third parties or service providers and affiliated companies?

All our service providers and affiliated companies are required to take appropriate security measures to protect your personal information. Where service providers or affiliated parties process your personal information on our behalf as “data processors” they must do so only on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

12.5 What about other third parties?

We may share your personal information with other third parties in the context of the possible sale or restructuring of the business where necessary in connection with the purposes which your information was collected for. We may also need to share your personal information with a regulator or to otherwise comply with the law.

13. WHERE WE STORE YOUR INFORMATION

13.1 Our office headquarters are based in Switzerland and our main data centre is located in Switzerland. Where required to perform our contract with you or for our wider business purposes, the information that we hold about you may be transferred to, and stored at, other destinations outside the UK and the EU. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.

13.2 Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an “adequacy decision” in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. ACTION NEEDED

13.3 If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required. To obtain more details of these safeguards, please contact us using the contact details set out above in Section 1.2.

14. DATA SECURITY

14.1 As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors

and other third parties who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.

14.2 We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.

15. HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

15.1 We have set out above indications of how long we generally keep your information. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

15.2 To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

15.3 In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

16. YOUR RIGHTS

16.1 Data protection law gives you a number of rights when it comes to personal information, we hold about you. The key rights are set out below. Under certain circumstances, by law you have the right to:

16.1.1 Be informed in a clear, transparent, and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.

16.1.2 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

16.1.3 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

16.1.4 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

16.1.5 Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.

16.1.6 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

16.1.7 Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.

16.1.8 Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing, and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.

16.1.9 Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority.

If you want to review, verify, correct, or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

16.2 No fee required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we are not required to provide you access to your personal information more than twice in a twelve-month period.

16.3 What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

16.4 Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.

17. YOUR CALIFORNIA PRIVACY RIGHTS

17.1 Shine the Light Law. Cal. Civ. Code 1798.83 (known as the ‘Shine the Light’ law) allows California residents to request disclosure of the personal information companies share with third parties for those third parties’ direct marketing purposes. As permitted under California law, in lieu of providing this information, we have adopted a policy of permitting you to opt-out of such disclosures of your personal information. Once we process your opt-out request, we will not disclose your personal information for those third parties’ direct marketing purposes. To opt-out, please contact our customer service department.

17.2 CCPA Privacy Notice.

17.2.1 The California Consumer Privacy Act (“CCPA”) provides California residents with certain rights regarding their personal information that is collected by businesses, including the right to request that a business disclose what personal information it has collected about them, the right to request the deletion of personal information collected from them, the right to opt-out of the sale of their personal information (if the business sells personal information), and the right not to receive discriminatory treatment for exercising any of their privacy rights under the CCPA. These rights apply only to California residents. Any terms defined in the CCPA (Cal. Civ. Code Section 1798.140) have the same meaning when used in this section.

17.2.2 Right To Know. You may request that we disclose to you the following information covering the preceding 12 months:

1. the categories of personal information we have collected about you;

2. the categories of sources from which the personal information was collected;

3. the business or commercial purpose for collecting or selling personal information;

4. the categories of third parties with which we share personal information;

5. the categories of personal information about you that we have sold and the categories of third parties to which the personal information was sold;

6. the categories of personal information about you that we have disclosed for a business purpose and the categories of third parties to which the personal information was disclosed; and

7. the specific pieces of personal information we have collected about you.

If you are a California resident, you may request the disclosure of the information listed above by submitting a request at support-us@pbswisstools.com. Such a request may be referred to as a “right to know” request. In the request, please specify whether you are seeking information about categories of personal information and/or specific pieces of personal information. Pursuant to California law, we will verify your identity before complying with any such request.

You also have the right to be informed, at or before the point of collection, as to the categories of personal information to be collected and the purposes for which the categories of personal information shall be used. We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you with notice consistent with this section.

17.2.3 Right To Delete. You have the right to request that we delete any personal information about you that we have collected from you, and that we direct any service provider to delete such personal information from its records. Such a request may be referred to as a “request to delete.” However, pursuant to the CCPA, your information may not be deleted under certain circumstances, including where maintenance of your personal information is necessary to: complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, to provide a good or service that you requested or that is reasonably anticipated within the context of your ongoing business relationship with us, or to otherwise perform a contract between us and you; detect security incidents; protect against or prosecute fraudulent or illegal activity; enable solely internal uses that are reasonably aligned with your

expectations based on your relationship with us; comply with a legal obligation; or otherwise use your information internally in a lawful manner that is compatible with the context in which you provided the information. For more information about these and other situations in which we may not delete your information, please see Cal. Civ. Code Section 1798.105(d).

You may request the deletion of such personal information by submitting a request at support-us@pbswisstools.com. In the request, please specify that you are requesting the deletion of personal information. Before deleting such personal information, we will verify your identity, as required by the CCPA. We will require you to provide personal information in order to verify your identity.

17.2.4 Authorized Agent. You may use an authorized agent to submit a right to know request or a request to delete. To use an authorized agent, you must provide the agent with signed permission. In addition, you may be required to verify your own identity with us and confirm you provided the agent with permission to submit the request. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Such requirements, however, will not apply where you have provided the agent with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.

17.2.5 Right To Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

17.2.6 Sale Of Personal Information. You have the right to know whether a business sells personal information. If a business sells personal information, you have the right to “opt-out” of such sales by directing the business not to sell their personal information. We do not knowingly sell personal information of minors under 13 years old.

17.2.7 Collection And Disclosure Of Personal Information. See Section 2 above, entitled “What Personal Information Do We Collect and For What Purposes,” for the categories of personal information we have collected in the last 12 months and the purposes for which the personal information is used. We also may use your personal information for a purpose described in Section 11 above, entitled “Why Else Do We Use Your Information.”

We collect this personal information directly from you or from the sources described in Section 9 above, entitled “Information We Receive from Third Parties.”

See Section 12 above, entitled “Sharing Your Information,” for more information about our sharing of personal information and the categories of third parties with which we share your personal information.

18. CHANGES TO THIS PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.

19. PRIVACY OFFICER

Officer: Francesco Leo Virisario

Email: f.leovirisario@pbswisstools.com