This data privacy policy (this "Policy") applies to your access and use of our website, www.rowainc.net, and any of our social media accounts accessible via our website (collectively, the "Site") and informs you about the handling of your personal data. To make the processing of your data comprehensible, we would like to provide you with the following information to give you an overview of these processing operations. This Policy contains general information about our handling of your data as well as information about your rights under certain state and federal laws and regulations in the United States ("U.S.").

THIS POLICY APPLIES ONLY TO YOUR USE OF OUR SITE IN THE UNITED STATES AND MAY NOT COMPLY WITH THE GENERAL DATA PROTECTION REGULATION AND THE FEDERAL DATA PROTECTION ACT.

We will inform you in detail about

1. General Data Processing
2. Data processing on our Site
3. Further data processing

The parties responsible for the processing of data provided via this Site are ROWA Inc. and its affiliated entities, including the parent company, ROWA GROUP Holding GmbH (hereinafter "we" or "us").

1. Contact
If you have any questions or feedback concerning this information or wish to contact us to assert your rights, please send your enquiry to:

Representative in the U.S.:

ROWA Inc.
110 Phyllis Dr
Croydon, PA 19021
Pennsylvania/USA
Phone: +1-609-567-8600
sales(at)rowainc.net 

Representative in the European Union:

ROWA GROUP Holding GmbH
Siemensstraße 1-9
25421 Pinneberg
GERMANY
Phone: +49-4101 706-06
Fax: +49-4101-706-201
info(at)rowa-group.com

2. Legal basis
The data protection term "personal data" refers to all information relating to an identified or identifiable natural person, which may include sensitive personal information.

"Sensitive personal information" refers to a specific subset of personal data that requires enhanced protection, including: government identifiers (e.g., social security numbers); an account log-in, financial account, debit card, or credit card number with any required security code, password, or credentials allowing access to an account; precise geolocation; contents of mail, email, and text messages; genetic data; biometric information processed to identify a consumer; information concerning a consumer’s health, sex life, or sexual orientation; or information about racial or ethnic origin, religious or philosophical beliefs, or union membership.

We process personal data in compliance with applicable data protection regulations, under U.S. state and federal laws and regulations. Your use of this Site constitutes your consent to our use and processing of your personal data in accordance with this policy. We will process personal data solely with your consent to perform a contract to which you are a party, to take steps at your request prior to entering into a contract, for compliance with a legal obligation, or where processing is necessary for the purposes of our legitimate interests or those of a third party.

3. Period of storage
In the absence of alternative provision ensuing from the following statements, we will only store your data for as long as required to achieve the intended processing purpose or to fulfill our contractual or statutory obligations. Such statutory retention requirements may result from regulations under commercial or tax law.

4. Recipients of data
We may use Service Providers for individual processes and may disclose your personal data to such Service Providers solely for such purposes. This includes, for example, hosting, maintenance and support of IT-systems, marketing actions or destruction of files and data carriers. These Service Providers process the data only according to strict instructions and are contractually bound to provide suitable technical and organizational measures for data protection. In addition, we may transfer personal data of our customers to parties such as postal and delivery services, payment and information services, banks, tax consultants/auditors or the tax authorities.

5. No Sale of Personal Data; Exceptions
Except as provided herein, personal data collected through the Site will not be sold or otherwise disclosed to third parties for direct marketing purposes. We may transfer your personal data as part of a merger, sale, or other transfer of our business or some or all of our assets.

6. No Collection of Information from Children
Our Site is not intended for children under 18 years of age. We do not knowingly solicit or collect any personal data from visitors under 18 years of age. Please do not use the Site if you are under the age of 18. If we learn we have collected or received personal data from a child under 18 without parental consent, we will promptly delete that information. If you believe we might have any personal data from or about a child under 18, please contact us immediately via email at datenschutz(at)rowa-group.com.

7. Aggregated and De-Identified Information
We may disclose aggregated and de-identified information about our users.

8. Additional Rights for Certain Residents
Residents of California
California residents may have additional rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CPRA) (Cal. Civ. Code § 1798.100 et seq. and collectively referred to as the "CCPA"), subject to certain limitations. No user of the Site will be discriminated against for exercising their rights under the CCPA.

As described in this Policy, we may collect various categories of personal data from users of the Site to provide our services and related support, analyze, personalize, and improve our services, engage in advertising, marketing and promotional activities, process sales, execute our internal operations, secure and protect our business, and comply with legal obligations.

Subject to certain exemptions, if you are a California resident, the CCPA grants you the following rights:

• Request to Know. California residents have a right to request a copy of particular information we have collected about you, up to two (2) times in a 12-month period, subject to certain exemptions. We will deliver this information, free of charge, by mail or electronically in a portable and, to the extent technically feasible, readily usable format that allows the requester to transmit this information to another entity without hindrance, which may include:
  • categories of personal data collected;
  • types of sources from which the personal data is collected;
  • business and/or commercial purposes for collecting and selling a user’s personal data; and the
  • categories of third parties with whom we have shared personal data.
• Request to Delete. California residents have a right to request that we delete any personal data about them that we have collected through the Site, subject to certain exceptions. If you are a California resident who makes such a request, once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.
  
  We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to do any of the following:
  • Complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect, prevent, or mitigate security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Use the personal data as necessary to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. Seq.).
  • Enable solely internal uses that are reasonably aligned with our normal operations and consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that personal data that are compatible with the context in which you provided it.
• Request to Correct. California residents have a right to request that we use commercially reasonable efforts to correct any personal data about them that we have collected through the Site which is inaccurate.

Only you, or someone legally authorized to act on your behalf, may make one of the above requests related to your personal data. You may also make a verifiable consumer request on behalf of your minor child. In order for us to act on one of these requests, we must be able to verify your identity or authority to make the request and confirm the personal data relates to you, and your request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request and will not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

• Right to Opt-out of Sale of Personal Data. The CCPA gives California residents 16 years of age or older the right to opt-out of the sale of their personal data at any time. This Siteis not intended for use by children, so we do not sell the personal data of consumers we know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal data sales may opt-out of future sales at any time.

Other States in the U.S.
In addition to California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide, or will provide in the near future, their state residents with certain rights which may include the right to:

• Confirm whether we process their personal data;
• Access and delete certain personal data;
• Correct inaccuracies in their personal data, taking into account the information's nature processing purpose;
• Data portability;
• Opt-out of personal data processing for: targeted advertising, sales; or behavioral profiling in furtherance of decisions that produce legal or similarly significant effects; and/or
• Limit our ability or require your consent to process sensitive personal information.

The exact scope of these rights varies by state. If you are a resident of a state with additional protections and would like to make any request as described herein, please contact us as provided in this Policy. We will respond to verifiable requests received from such states’ residents as required by law.

Residents of the European Union

• Pursuant to Art. 15 GDPR and § 34 BDSG, you have the right to request information confirming whether or not and, if so, to what extent we are processing personal data concerning you. 
• Pursuant to Art. 16 GDPR, you have the right correct your data.
• Pursuant to Art. 17 GDPR and § 35 BDSG, you have the right to delete personal data.
• Pursuant to Art. 18 GDPR, you have the right to require that we restrict the processing of your personal data.
• Pursuant to Art. 20 GDPR, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller.
• Where you have granted us separate consent to process your data, you can withdraw such consent at any time pursuant to Art. 7 Sec. 3 GDPR. Any such withdrawal of consent shall not affect the lawfulness of processing based on that consent prior to its withdrawal.
• If you consider that the processing of personal data relating to you infringes GDPR provisions, you have the right to lodge a complaint with a supervisory authority pursuant to Art.77 GDPR.
• If you exercise your rights pursuant to Art. 12 to 22 GDPR for the purpose of providing information and preparing such information, we will process stored data only for this purpose and for purposes of data protection control and otherwise restrict processing in accordance with Art. 18 GDPR. These processing operations are based on the legal basis of Art. 6 Sec. 1 letter c) GDPR in combination with Art. 15 to 22 GDPR and § 34 Sec. 2 BDSG.

9. Data protection officer
You can contact our data protection officer using the following address:
datenschutz(at)rowa-group.com

When using our Site, we collect and use information that you provide by yourself. We also collect and use personal data for any purpose for which you provide your consent. We also automatically collect certain information about your use of the Site during your visit on the Site. In data protection law, the IP address is also considered as a personal data. An IP address is assigned to each device connected to the Internet by the Internet provider so that it can send and receive data.

1. Processing Server-Log-Files
When using our Site for purely informative purposes, general information that your browser transmits to our server is initially stored automatically (not via registration). This includes by default: browser type/-version, operating system used, page called, the previously visited page (referrer URL), IP address, date and time of server request and HTTP status code. The processing is carried out to ensure our legitimate interests as legally permitted under applicable U.S. state and federal laws. This processing provides the technical administration and security of the Site. The stored data will be deleted after 14 days unless there is a justified suspicion of illegal use based on concrete indications and further examination and processing of the information is necessary for this reason. We are not able to identify you as a data subject based on the stored information.

2. Data transmission to the European Union
Visiting our Site may involve the transmission of certain personal data to the European Union, as our parent company, ROWA Group Holding GmbH, is based in the European Union, and the webserver for the Site is stationed in Germany. The transfer of certain personal data to the European Union will take place in a permissible manner in accordance with this Policy.

3. Contact form and requests
Our Site contains a contact form through which you can use to send us messages. The transfer of your data is encrypted (recognizable by the "https" in the address bar of the browser). All data fields marked as mandatory fields are required to process your request. Non-provision of this information means that we cannot process your request. The provision of further data is voluntary. Alternatively, you can also send us a message via the following contact e-mail: dave.baglia@rowainc.net.

We process data, including personal data, for the purpose of answering your request. If your request is directed to the conclusion or execution of a contract with us, that constitutes the legal basis for the data processing under applicable U.S. state and federal laws. Otherwise, we process the data on the basis of our legitimate interest in contacting the persons requesting information as legally permitted under applicable U.S. state and federal laws.

4. Cookies
We use cookies on our Site. Cookies are small text files that are stored by your browser when you visit a Site. This identifies the browser used and can be recognized by our web server. . We use these cookies only as necessary for our legitimate purposes or those of our third-party relationships as legally permitted under applicable U.S. state and federal laws. This processing serves our legitimate interest in making our Site more user-friendly, effective and secure. We used so-called "session cookies," which are deleted when the browser session is closed. You can delete the cookies in the security settings of your browser at any time. You can object to the use of cookies through your browser settings in principle or in certain cases.

5. Integrated services and third-party content
We use services and content (collectively, "Content") provided on our Site by third parties. For such an integration a processing of your IP address is technically necessary, so that the contents can be sent to your browser. Your IP address will therefore be transmitted to the respective third-party providers. This data processing is carried out in order to safeguard our legitimate interests in the optimization and economic operation of our Site as legally permitted under applicable U.S. state and federal laws. You can object to this data processing at any time via the settings of the browser used or certain browser extensions. One such extension is the uMatrix matrix-based firewall for the Firefox and Google Chrome browsers. Please note that this may result in functional restrictions on the Site.

1. Contractual relationship
In order to establish or execute the contractual relationship with our customers, it is regularly necessary to process the contact data of the relevant contact persons provided to us. The processing serves our legitimate interest in a fluent course of business as legally permitted under applicable U.S. state and federal laws. In addition, we process customer and potential customer data for evaluation and marketing purposes and to serve our interest in further developing our offer and informing you specifically about offers from ROWA Inc. / ROWA Group USA, LLC, as legally permitted under applicable U.S. state and federal laws. Further data processing can take place if you have consented as legally permitted under applicable U.S. state and federal laws or if it serves to fulfill a legal obligation.

2. Applications
When you apply for a position at our company, we process your application data exclusively for purposes related to your interest in current or future employment with us. Your application will only be processed and acknowledged by the responsible contact person. All employees entrusted with data processing are obliged to maintain the confidentiality of your data. If we are unable to offer you an employment, we will retain the data you provide for up to three months for the purpose of potentially answering questions relating to your application and rejection. This does not apply if legal provisions prevent deletion, if further storage is necessary for the purpose of presenting evidence or if you have expressly consented to longer storage as legally permitted under applicable U.S. state and federal laws. If we keep your applicant data for a period of six months and you have expressly consented to this, we would like to point out that this consent can be freely revoked at any time. Such a revocation does not affect the legality of the processing, which has taken place until the revocation on the basis of the consent.

3. Offline Orders
If you order a product via our order form or by telephone, we process personal data exclusively for contract processing or to be able to provide you with the ordered product. Within the ordering process, we only process the data that you have provided yourself. In order to be able to deliver the ordered products to you, we transmit the data required for delivery to one of our shipping service providers as specified in the order as legally permitted under applicable U.S. state and federal laws. All data fields marked as mandatory fields are required for processing your order. Non-provision of this information means that we cannot process your order. The provision of further data is voluntary.

4. Usercentrics
Your consent data will be processed for the use of this Site and the use of the implemented Consent Management Platform. We use the Google Cloud Platform, provided by Google Cloud EMEA Ltd. The servers are located in Germany and Belgium. We would like to inform you that we cannot exclude the fact that data may be subject to access by the U.S. security authorities in accordance with 50 U.S.C. §1881(b)(4), 50 U.S.C. §1881a (FISA 702). In the event that personal data is transferred within the U.S. or to foregin jurisdictions, we have taken reasonable measures with Google in accordance with applicable U.S. state and federal laws. More information can be found in the Data Protection references of Google (https://safety.google/security-privacy/). Additionally we have taken further safety measures designed to ensure the security of the data.

5. hCaptcha
A Note to Customers Outside the U.S.: We use the hCaptcha security service on our Site. This service is provided by Intuition Machines, Inc. ("IMI"). IMI is based in the U.S. The Site and our services are controlled and operated by us from the U.S. Your personal data may be stored and processed in the U.S. and in any country where we have facilities or in which we engage service providers, and by using the Site and our services you consent to the transfer of information to countries outside of your country of residence, including the U.S., which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.

6. Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is a tool that enables us to integrate tracking or statistical tools and other technologies on our Site. The Google Tag Manager itself does not create any user profiles, does not store any cookies and does not carry out any independent analyses. Although, the Google Tag Manager itself does not set cookies, it can transmit cookies because the tags used can set cookies. In addition, when the Google Tag Manager is called up, the IP address and browser fingerprint are transmitted to Google. This represents data collection, and this is considered data processing under applicable data privacy laws for which your consent may be required. Your use of this Site constitutes your consent to our use and processing of your personal data in accordance with this policy. Consent can be revoked at any time.

The Site operator has a legitimate interest in the fast and uncomplicated integration and management of various tools on its Site. If a corresponding consent has been requested, the processing is carried out exclusively as legally permitted under applicable U.S. state and federal laws.

7. Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House Barrow Street Dublin 4, Ireland (hereinafter: Google). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

Google Analytics processes personal data on your behalf. Google transfers that data between the U.S. and Europe to process it. Even though they have a registered entity in Ireland, they are still subject to US law, including the FISA 702 and the CLOUD Act. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Site. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the Site (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout

Google Analytics is used on this Site with IP anonymization. This means that IP addresses are further processed in abbreviated form, thus excluding the possibility of personal references. If the data collected about you is personally identifiable, it is immediately excluded and the personal data is deleted immediately.

We use Google Analytics to analyze the use of our Site in order to regularly improve the user experience. We can use the statistics obtained to improve our offer and make it more interesting for you. We also receive information about the functionality of our Site (e.g. to identify navigation problems). Transfers to third countries are possible. For further information (such as a copy of the guarantees), you can contact the contact details listed under 1.

8. Google Adwords
On this Site, we use Google Adwords from Google Ireland Limited, Gordon House Barrow Street Dublin 4, Ireland (hereinafter: Google) to draw attention to our offers with the help of advertising material (so-called Google Adwords) on external Sites. We can determine how successful the individual advertising measures are in relation to the advertising campaign data. We are interested in showing you advertising that is of interest to you, making our Site more interesting for you and achieving a fair calculation of advertising costs.

These advertising materials are delivered by Google via so-called "ad servers". For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as the display of ads or clicks by users, can be measured. If you access our Site via a Google ad, Google Adwords will store a cookie on your computer. The unique cookie ID, the number of ad impressions per placement (frequency), the last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie. These cookies enable Google to recognize your internet browser. If a user visits certain pages of an Adwords customer's Site and the cookie stored on their computer has not yet expired, Google and the customer can recognize that the user clicked on the ad and was redirected to this page. A different cookie is assigned to each Adwords customer. Cookies can therefore not be tracked via the Sites of Adwords customers. Ad server cookies generally lose their validity after 30 days and are not intended to identify you personally.

We ourselves do not collect and process any personal data in the aforementioned advertising measures. We only receive statistical evaluations from Google. Based on these evaluations, we can recognize which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material; in particular, we cannot identify users on the basis of this information. Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server.

You can prevent participation in this tracking process in various ways: a) by setting your browser software accordingly - suppressing third-party cookies means that you will not receive any ads from third-party providers; b) by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain https://adssettings.google.com/anonymous?hl=en with this setting being deleted when you delete your cookies; c) by deactivating the interest-based ads of the providers that are part of the "About Ads" self-regulation campaign via the link https://www.aboutads.info/choices, with this setting being deleted when you delete your cookies; d) by permanently deactivating them in your Firefox, Internet Explorer or Google Chrome browsers under the link https://www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to use all functions of this Site to their full extent.

Further information on the purpose and scope of data collection and its processing, as well as further information on your rights in this regard and setting options to protect your privacy, can be found in Google's privacy policy for advertising: https://policies.google.com/privacy/embedded?hl=en-US