Privacy Principles


The Triangle Group Co., Ltd and its affiliates (collectively, "Triangle Tire") respects individual privacy and values the confidence of its associates, customers, vendors and others with whom we do business. Triangle Tire strives to collect, use and disclose Personal Information in a manner consistent with the laws of the countries in which it does business, and prides itself on upholding the highest ethical standards in its business practices.

This Global Privacy Policy sets forth the general privacy principles that Triangle Tire follows with respect to Personal Information that it gathers, processes, stores and discloses in its business operations.

Scope

This Policy applies to all Personally Identifiable Information (PII), in any format or medium, relating to all employees, customers, vendors and others who do business with Triangle Tire.

Definitions

For purposes of this Policy, the following definitions shall apply:

"Personal Information" means any information or set of information, whether alone or in combination with other Personal Information gathered, processed, used or stored by Triangle Tire that is sufficient to identify an employee, or other individual. Personal Information does not include information that is anonymous, nor does it include publicly available information that has not been combined with non-public Personal Information.

"Triangle Tire" means The Triangle Tire Tire & Rubber Company and its affiliates as used in this Policy.

Privacy Principles

Triangle Tire, when gathering, processing, storing, using or disclosing Personal Information, shall follow these principles:

Notice and Consent: Triangle Tire endeavors to inform persons whose Personal Information Triangle Tire collects about the purposes for which it collects and uses the Personal Information, the types of third parties to which Triangle Tire discloses or may disclose that information, and the choices and means Triangle Tire offers the subjects of the information for limiting the use and disclosure of their Personal Information. Triangle Tire will endeavor to provide notice when persons are first asked to provide Personal Information to Triangle Tire, or as soon as practicable thereafter, and in any event before Triangle Tire uses or discloses the information for a purpose other than that for which it was originally collected. Unless permitted by applicable law, no Personal Information is collected without first obtaining the consent of the individual for the collection, use and disclosure of that information. In some circumstances that consent may arise from the nature of the relationship between Triangle Tire and the individual. When you provide information to Triangle Tire you consent to our collection, use and disclosure of your Personal Information in accordance with this Policy and other applicable Triangle Tire privacy policies. You may, as provided by applicable law, be free to refuse or withdraw your consent upon reasonable advance notice. Triangle Tire will endeavor to advise you of the consequences of withdrawing your consent.

Choice: Triangle Tire will endeavor to offer persons whose information it possesses an opportunity, where feasible and reasonable under the circumstances, to choose whether their Personal Information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Triangle Tire will endeavor to provide individuals with mechanisms, reasonable under the circumstances, to exercise their choice.

Access and Correction: Upon request and where required or otherwise appropriate, and within periods (if any) set by applicable law, Triangle Tire will endeavor to grant individuals reasonable access to the Personal Information that it holds about them. Such access may be denied by Triangle Tire where such denial is permitted by applicable law and where (i) such access could potentially disclose Personal Information of another individual, and therefore, violate his/her privacy rights; (ii) such access could potentially disclose information relating to any ongoing Triangle Tire investigation; (iii) such access could potentially disclose Triangle Tire’s confidential information; (iv) the cost of such access would be significantly disproportionate to the benefits derived; (v) Triangle Tire has a good faith belief that the request is not to correct data but to hide or alter data that could adversely affect the individual requesting the correction; and (vi) at any point it becomes clear that any individual's access requests are unjustified or harassing in nature. In the event a request is denied, Triangle Tire will notify the individual regarding the reasons for denial in writing. Consistent with how your information is maintained in the ordinary course of Triangle Tire's business, Triangle Tire will provide the information in an understandable form. We may impose a reasonable charge when a request is made (e.g., for photocopying or postage). In addition, Triangle Tire will endeavor to take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. To guard against fraudulent requests for access, Triangle Tire may require sufficient information to allow it to confirm the identity of the individual making the request before granting access.

Data Integrity: Triangle Tire will endeavor to use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Triangle Tire will endeavor to take reasonable steps to ensure that Personal Information is relevant to its intended use, accurate, complete, and current.

Disclosure and Transfer to Third Parties: Triangle Tire will endeavor to obtain appropriate and reasonably enforceable assurances from third parties to which it discloses or transfers Personal Information that they will safeguard Personal Information in a manner consistent with this Policy. Where Triangle Tire becomes aware that a third party is using or disclosing Personal Information in a manner contrary to this Policy, Triangle Tire will endeavor to take reasonable steps to prevent or stop such use or disclosure. To the extent applicable law requires your consent before disclosing your Personal Information to third parties we will endeavor to obtain your consent prior to such transfer. There may be circumstances where we will be required to transfer Personal Information without obtaining prior consent, including (i) where required by a court order; (ii) where Triangle Tire believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, or safety or property of a person or group of persons; (iii) where it is necessary to establish or collect monies owing to Triangle Tire or to complete a transaction with a third party; (iv) where it is necessary to permit Triangle Tire to pursue available remedies or limit any damages we may sustain; or (v) where the information is public. Where obliged or permitted to disclose Personal Information, Triangle Tire will not disclose more than is required.

Because Triangle Tire does business in many countries, information collected by Triangle Tire in one country may be processed in another country, including the United States of America, whose laws may provide different levels of protection from those in the country where the information is first collected. Personal Information gathered in one country may be subject to access by and disclosure to law enforcement agencies of jurisdictions other than the country where the information is first collected. Triangle Tire also may share Personal Information with organizations and entities that perform services on its behalf, and these organizations and entities may be located in countries other than the country in which the information is first collected.

Triangle Tire may also make disclosures permitted by its online privacy policy.

Security: Triangle Tire takes reasonable and appropriate precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, and to respond to the misuse, loss or unauthorized use of such information.

Governance: Triangle Tire will regularly review compliance with this and other Triangle Tire privacy policies. Except to the extent otherwise prohibited by applicable law, any Triangle Tire employee, associate or contractor that Triangle Tire determines is in violation of this Policy will be subject to appropriate disciplinary action up to and including termination of employment or engagement.

Dispute Resolution: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to Triangle Tire at the address given below. Triangle Tire will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.

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