Last Updated / Effective Date: April 15, 2020

Ovention, Inc. (“Ovention,” “we,” “us,” or “our”) understands that privacy is important to our customers and the visitors to our website (“Site”).  This Privacy Policy describes the information that is collected through your interactions with Ovention and this Site, and how that Personal Information is collected, stored, and used.

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BY ACCESSING OR USING THIS SITE, YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY AND CONSENT TO THE COLLECTION AND USE OF PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.  IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU SHOULD NOT ACCESS THIS SITE.

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1. CONSENT TO OVENTION TERMS.
   If you use the Site, you must comply with our Terms of Use found at [https://oventionovens.com/terms-of-use/Ovention] (“Terms”).  If you do not agree to the Terms, you may not use the Site.

2. MODIFICATIONS TO THIS PRIVACY POLICY. WE MAY MODIFY THIS PRIVACY POLICY AT ANY TIME BY POSTING UPDATES TO THE SITE.  YOU ARE ADVISED TO CHECK BACK PERIODICALLY FOR UPDATES.  YOUR CONTINUED USE OF THE SITE AFTER THE POSTING OF AN UPDATED PRIVACY POLICY IS CONSIDERED AGREEMENT TO THE UPDATED PRIVACY POLICY.

3. COLLECTION OF INFORMATION. Ovention may collect and store the following types of information about you:

 A) Personal_Information. Ovention may collect and store Personal Information about you.  Personal Information is information that can be used to identify, locate or contact you, such as your name, email address, phone number, mailing address, driver’s license number and date of birth (“Personal Information”).

 i. Employment Information. Ovention will collect Employment Information from you when you apply for jobs with Ovention or our parent company Hatco Corporation.  In addition to the information described above in Section 3A, “Employment Information” may include your educational history, criminal history, past and current employment experience and status, your legal authorization to work in the United States, skills and qualifications, and references, unless collection of such information is prohibited by applicable laws.

B) Non-Personal Information. Ovention may collect and store Non-Personal Information about you.  Non-Personal Information is information or data that does not personally identify you and is not readily available for that purpose (“Non-Personal Information”).  Examples of Non-Personal Information include your type of browser, operating system, search requests, website traffic information, the date and time you visited our Site, the amount of time you used the Site, the pages you visited on our Site, any device you are using to access the Site, network, geographic and language information and any hyperlinks you click on when using the Site.

i. De-Identified Data. Any Personal Information that has been de-identified and/or aggregated so that it no longer contains Personal Information will be treated as Non-Personal Information.  Non-Personal Information will not be re-combined with other information to create Personal Information.

ii. IP Address and Geolocation. Internet Protocol (“IP”) address and geolocation will be treated as Non-Personal Information except where otherwise expressly required by applicable law.

 C) Information We Do Not Intend To Collect:

i. Special Categories of Personal Data. “Special Categories of Personal Data” or “Special Data” is any data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation.  Except for the Special Needs information mentioned above, the data Ovention collects and processes does not qualify as Special Data.  We do not intend to collect any other Special Data from you.  Please refrain from entering or posting any other Special Data while using the Site, or sending any other Special Data to us.

ii. Information from Children. This Site is not directed toward children under 16 years of age and Ovention requests that children under 16 do not provide Personal Information through this Site.  If you believe your child has provided Personal Information to us, you may contact us at socialmedia@oventionovens.com and provide us any relevant information needed, such as the Personal Information your child provided, and we will make reasonable attempts to delete such information.

 4. HOW WE COLLECT INFORMATION FROM YOU.

 A) When You Communicate With Us. We collect Personal Information when you voluntarily provide it to us and communicate with us, for example, when you call, mail or email us, or when you post on the Site.

B) When You Create an Account. We collect Personal Information when you register for any of the various types of registered accounts through the Site (each an “Account,” collectively, the “Accounts”).

i. Registered Accounts. When our customers establish a Registered Account, or when Ovention establishes a Registered Account for its representatives, we collect a person’s first and last name, email address, and (optional) telephone number.  We also collect other business information such as customer and invoice number and invoice amount.

C) Signing Up for the Newsletter. If you sign-up or otherwise opt-in to receive promotions or other communications from us, including the newsletter, you will need to submit your email address. We will use this information to provide you with promotional and other electronic communications.  You may opt-out of promotional emails by following the unsubscribe information in the applicable email.

D) Applying for Jobs with Hatco or Ovention. If you apply for a job through the Site or send us a resume or other application materials to apply to work for Ovention or its parent company Hatco Corporation, we will only use those materials to evaluate your qualifications to work for Ovention or its affiliates, and to otherwise consider or respond to your inquiry.  Your submission of a job application or resume does not require Ovention to review it or consider you for employment.  You represent to Ovention that all information you provide in connection with your application for employment is true and accurate to the best of your knowledge.

E) Social Media. We may collect and store any information that you post on our Social Media (defined below) accounts.

 F) Cookies and Other Tracking. We automatically collect and store cookies and web beacons when you use the Site.  Cookies are small text files that our server downloads onto your computer or electronic device when you use the Site that provide us information about your activities.  Web beacons are small graphics on a webpage or email that monitor your activity when viewing a webpage or email.  These types of tracking devices help us learn more about our users and allow us to improve our Site and services to you.  Our Cookie Policy provides more information about how we collect and process these types of tracking devices, and can be found at [https://oventionovens.com/cookie-policy/] (“Cookie Policy”).  The Cookie Policy is part of this Privacy Policy.

G) Analytics. We may use third-party analytics companies, such as Google Analytics, to analyze the usage of our Site for internal purposes.  These analytics companies may use cookies and other tracking mechanisms to collect data about how you use our Site and provide us with aggregate information on such usage, which helps us improve the performance of our Site.

5. DO NOT TRACK SIGNALS. We do not currently honor “do not track”

6. HOW DO WE USE YOUR PERSONAL INFORMATION? We use your Personal Information in compliance with applicable laws.  We use your Personal Information as was stated (or obvious) at the point of collection.  We also use your Personal Information in the following ways:A) To respond to your questions, comments, or complaints (including copyright infringement notices and counter-notices);B) To create and manage your Account(s);C) To facilitate transactions;

D) To send you promotions or targeted advertising;

E) To troubleshoot problems with the Site;

F) To improve the content and functionality of the Site and the services we provide to our customers;

G) To perform statistical analysis and other analyses of the Site;

H) To promote our products and other services sold on the site;

I) To notify you of new services, new features of the Site, changes to the Terms or Privacy Policy, or other similar communications;

J) To facilitate our training programs;

K) To review and evaluate applicants for employment, including to follow-up with references provided to us;

L) To provide you with our newsletter;

M) To protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Site, or to other users of the Site; and

N) As requested by or consented to by you.

7. SHARING YOUR PERSONAL INFORMATION. We do not sell, rent or lease your Personal Information to any third party.  We limit the parties with whom we share your Personal Information.  We may share your Personal Information with the following parties:A) Employees and Affiliates. Our employees and affiliates who have a need to know the information for our business purposes.

 B) Third-Party Service Providers. We may share your Personal Information with our third-party service providers and our representatives that provide certain services for Ovention.  We share your Personal Information with our third-party service providers that host and manage the Site or that provide services through the Site.  We share your Personal Information with our third-party service providers to:  (i) provide targeted advertising and other marketing; (ii) improve the content and functionality of the Site, (iii) perform data analysis and statistical analysis, and (iv) troubleshoot problems with the Site.

C) Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, including by disclosing your Personal Information, if you are suspected of violating applicable laws.  We may disclose your Personal Information to governmental officials, law enforcement or other similar governmental personnel:  (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose your Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Ovention or any other party.

 D) Professional Advisors. Our professional advisors, such as our attorneys, accountants, financial and business advisors, in their capacity as advisors to Ovention.

 E) Other Users. By submitting a copyright infringement notice, counter-notice or other similar notification through the Site or to Ovention, you consent to having that communication forwarded to any person or entity to whom the notice or counter-notice is relating in order to facilitate a prompt resolution of the copyright infringement claim.

F) Change in Ownership. In the event Ovention is the subject of a change of control transaction such as a merger, acquisition, sale of all or substantially all of our assets or equity, in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or similar transaction, we may provide your Personal Information to the subsequent owner(s).

G) Other. We may share your Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure from the context of collection).

8. USING AND SHARING NON-PERSONAL INFORMATION. Ovention is the sole and exclusive owner of any Non-Personal Information received or created by Ovention or its third-party service providers or licensors.  We may use or disclose to third-parties Non-Personal Information for any business purpose as determined in our sole discretion, in compliance with applicable laws.
9. ONLINE ADVERTISING. Ovention uses its third-party service provider Multiview to participate in interest-based advertising, tailored to your physical location and history with the Ovention Site.  This advertising may be shown across any number of websites and Social Media networks across the internet.  Some websites where Ovention may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites.  Those ads include advertising for Ovention, but no Personal Information about you is shared with those third-party ad networks.

Other sites where you see our ads may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you.  Information collected by our advertising service providers through cookies and other technologies may include browsing behavior, referring sites and your response to advertisements.  These cookies do not collect Personal Information.  The information we collect in this manner is only used to improve our advertising.

If you receive a behaviorally targeted advertisement, you may click on the displayed icon to receive more information and you may choose to opt-out.  Your opt-out choices may be affected by your use of a specific device, your browser settings or your log-on credentials.  Please refer to the website that you are visiting, your browser and/or your device settings for additional information.  If you opt out, you may still receive online advertising from Ovention, which is based on your preferences or online behavior.  Ovention uses multiple online advertising programs, so opting out of one program does not opt you out from all online advertising.

Furthermore, when you submit Personal Information through the “Contact Us” or “Request a Demo” feature of the Site, your Personal Information may be sent to a representative in your area to provide you further information regarding our products or services.

In addition, the Site may also use the advertising services and networks offered by Social Media platforms to deliver advertising content.  Use of Social Media services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you are accessing the Site.

10. SECURITY. Ovention uses appropriate technical and organizational measures to ensure a level of security appropriate to the risk for all personal data processed.  This Site has commercially reasonable security measures in place to help protect against the loss, misuse and alteration of the information under our control.  While we cannot guarantee that loss, misuse or alteration to data will not occur, Ovention uses industry standard protections to help safeguard against such occurrences.  In the event that a breach into our security systems occurs and there is a possibility that an unauthorized person acquires your Personal Information, Ovention will notify you of the breach as required under applicable law.

YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR A MOBILE DEVICE CAN BE GUARANTEED TO BE 100% SECURE.  WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF ANY PERSONAL INFORMATION AND YOU PROVIDE SUCH PERSONAL INFORMATION AT YOUR OWN RISK.

11. SOCIAL MEDIA. Ovention is active on social media, including Facebook, Twitter, YouTube, Vimeo, Instagram and LinkedIn (“Social Media”).  You have the opportunity to comment on those Social Media platforms regarding Ovention and the programs, products and services we offer.  Any content you post on a Social Media platform will be treated as non-confidential information.  Ovention reserves the right to post (or re-post) on the Site and its Social Media pages any comments or content that you post on our Social Media pages.

The Site allows you to connect to and share information with various Social Media platforms.  These features may require us to implement cookies, plug-ins and application protocol interfaces (APIs) provided by those Social Media platforms to facilitate those communications and features.

Anything you post on Social Media is public information.  YOU AGREE TO HOLD OVENTION AND ITS AFFILIATES HARMLESS AND WITHOUT LIABILITY FOR THE RESULTS OF ANY AND ALL CONTENT YOU POST TO OVENTION’S SOCIAL MEDIA PAGES.

Your use of Social Media platforms, and the collection, use and sharing of Personal Information is governed by the privacy policies and terms of the third parties that own and operate those sites and NOT by this Privacy Policy.  We encourage you to review the privacy policies of those third-party Social Media platforms.

12. THIRD-PARTY SITES. This Site may link to, or be linked to, other Sites not maintained by or related to Ovention.  Ovention is not responsible for the privacy policies or practices of any third parties or third-party websites, including any linked or linking websites.  To the extent that you disclose Personal Information to any such third parties, the privacy policies and terms of those third parties, and not this Privacy Policy, apply to their use of your Personal Information.A) CALIFORNIA RESIDENTS.  Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by emailing socialmedia@oventionovens.com or calling our toll-free phone number at (855)-298-6836.

13. The California Consumer Privacy Act (CCPA), provides California consumers specific rights regarding their personal information. This section briefly describes these rights and how to exercise them. You have:1) The Right to Know what personal information is collected, how it is processed, for what purpose, and with whom it is shared. You can request that we disclose information about how we collect and use your personal information over the last twelve (12) months. As soon as we verify your request, we will disclose:

1. 1. What information we have collected about you. See Section 3 above.
   2. Our business purpose for collecting this information. See Section 7.
   3. The categories of third parties with whom we have shared this information. See Section 3A.
   4. If we have disclosed your information for a business purpose. See Section 8

2) The Right to Delete personal information that you have provided to us previously.

i. You or someone you authorize to make this request on your behalf may request any of this information by emailing socialmedia@oventionovens.com or calling our toll-free phone number at (855)-298-6836.. In order to provide all necessary information, you must send us sufficient information for us to verify that you are the person that you are requesting date for, and describe your request clearly, so we may respond to it.

3) The Right to Opt-Out from the sale of your personal information.

i. We do not sell your personal information.

4) The Right to Non-Discrimination in terms of what quality of price, service, or other communications we provide to you.

14. COMMUNICATING WITH YOU. You agree that we may contact you in response to communications from you, to provide you with promotional emails, to provide you information about your Accounts or your orders, and to provide you information about the Site.  If you do not wish to receive certain promotional emails, you may opt-out by clicking the “unsubscribe” button at the bottom of that email.
15. CONSENT TO PROCESSING IN THE UNITED STATES. By providing Personal Information to us, you understand and consent to the collection and processing of your Personal Information in the United States, regardless that certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the European Union or other jurisdictions.
16. GOVERNING LAW. Unless otherwise expressly required by the applicable law of your country of residence, this Privacy Policy is governed by the laws of the State of Delaware, United States, without regard to conflict of laws principles.

17. DATA RETENTION. Ovention will only keep your Personal Information for so long as it has a reasonable business purpose for doing so.

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18. TERMS APPLICABLE TO PERSONS LOCATED IN THE EUROPEAN UNION. The purpose of this Section 18 is to provide information regarding additional terms that apply regarding Ovention’s processing of personal data of persons located in the European Union (“EU”) in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”).  THIS SECTION 18 ONLY APPLIES TO YOU IF YOU ARE LOCATED IN THE EU.

In the event of a conflict between this Section 18 and the remainder of this Privacy Policy, this Section 18 shall control for those persons located in the EU.

A) Definitions. The terms “personal data” and “processing” have the same meanings set forth under GDPR.  Those definitions are set forth below for your convenience:

 i. “personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

ii. “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 Furthermore, as used in this Section 18, the following definition(s) shall apply:

 iii. “Automated Decision” means an automated decision made about an individual person, including profiling, often where meaningful logic is involved, that produces legal effects that significantly affects the involved individual.

B) Processing of personal data. Personal Information, as defined above, is considered personal data under GDPR.  Furthermore, if any Non-Personal Information, as defined above, also qualifies as personal data under GDPR, then it shall be considered and treated as personal data for those persons located in the EU.

C) The European Economic Area (“EEA”). The EEA consists of the EU plus Norway, Iceland and Liechtenstein.  In the event that the EEA adopts GDPR in the future, then all references to the EU in this Section 18 shall instead refer to the EEA.

D) Switzerland. In the event you are a resident of Switzerland, your personal data shall be treated in compliance with the terms of this Section 18, except to the extent otherwise required by the Swiss Federal Data Protection Act.

E) Legal basis for processing. When Ovention processes your personal data, it has a legal basis for doing so as required under GDPR.  Ovention will only process your personal data if:  (i) it has received your express opt-in consent for such processing, (ii) the processing is necessary for performance of a contract, (iii) the processing is necessary for a legal obligation to which Ovention is subject, (iv) the processing is necessary to protect the vital interests of the data subject, (v) the processing is necessary for a task carried out in the public interest, or (vi) if Ovention or a third party has a legitimate interest that is not overridden by the interests or fundamental rights and freedoms of the data subject.

We have set out in the table below the reasons why we process Personal Data, the associated legal basis for Ovention’s processing of such personal data, and the type of personal data.  If Ovention is required to process any personal data for reasons (iii), (iv) or (v), those reasons may not be known to Ovention today and therefore may not be listed below, but examples are listed in Sections 7 and 8 above.

 F) Right to Withdraw Consent. In the event you provide your consent for us to process your personal data, you may withdraw your consent at any time by emailing socialmedia@oventionovens.com to request such change at no additional cost.

 G) Marketing. Ovention does not process personal data for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so.  You have the right to object to the processing of personal data for marketing purposes at any time by contacting us at socialmedia@Oventionovens.com.

 H) Automated Decision Making. Ovention does not make any Automated Decisions on your behalf or about you without first obtaining your express, opt-in consent.  In the event we secure your consent to do so, you have the right to object to the processing of personal data via Automated Decision making at any time by contacting us at socialmedia@Oventionovens.com.

 I) Your Rights & Choices. GDPR provides certain rights to individuals in relation to their personal data. Accordingly, you may have the following rights under GDPR, although some exceptions do apply.  We will comply with any requests made relating to the following rights if required by applicable law.  We may require you to prove your identity before we modify, provide, delete or transfer your personal data.

 i. Right of Access – You have the right to be informed of and request access to the personal data we process about you. This allows you to receive a copy of the personal data we hold about you.

 ii. Right to Rectification – You have the right to request that we amend or update inaccurate or incomplete personal data.

 iii. Right to Erasure (Deletion) – Under certain circumstances, you have the right to request deletion of your personal data.

 iv. Right to Restrict – Under certain circumstances, you have the right to request that we temporarily or permanently stop processing all or some of your personal data.

 v. Right to Object – Under certain circumstances, you have the right to object to Ovention processing personal data, such as for direct marketing purposes or when Automated Decision making is used.

 vi. Right to Data Portability – You have the right to request a copy of your personal data in electronic format and further request that we send such personal data to another party.

 vii. Communication Preferences and Opt-Outs – You have the right to stop receiving communications from us at any time by contacting socialmedia@Oventionovens.com, at no additional cost.

 viii. Right to Lodge a Complaint – You have the right to lodge a complaint with the applicable supervisory authority.

 If you have any questions about your privacy, your rights and choices, or how to exercise them, please contact us with your request at socialmedia@Oventionovens.com.  We will respond to your request within a reasonable period of time.

J) PROVIDING PERSONAL DATA DUE TO A CONTRACTUAL REQUIREMENT. You must provide personal data necessary to enter into certain agreements with Ovention, such as to apply for and/or attend Ovention’s Training School, to make certain purchases and in certain employment circumstances.

 K) THE CONSEQUENCES OF NOT PROVIDING PERSONAL DATA. Ovention will not be able to provide certain services to you without processing certain personal data such as processing job applications, selling you products, or reviewing applications to the Ovention Training School.  Furthermore, if you turn off certain tracking devices or decline certain cookies on the Site, certain features of the Site may not work.

 L) TRANSFER TO THIRD PARTIES AND COUNTRIES. Personal data that we collect or receive may be transferred to and/or processed by third parties that are located outside of the EU.  We transfer personal data to Brilliant Metrics who is located in the United States.  Some authorities in other jurisdictions believe the United States does not provide the same level of protection of personal data as in the EU, and EU authorities have determined the United States does not provide an adequate level of protection for personal data.  Ovention will only transfer EU data subject’s personal data to third-parties located outside of the EU when Ovention has ensured appropriate safeguards for such personal data, either through (i) the standard contractual clauses with such third party or (ii) verification that such third-party is EU-U.S. Privacy Shield certified (in the case of the United States).

 You may request a copy of any such appropriate safeguards or seek inquiries regarding such safeguards by contacting us socialmedia@Oventionovens.com.  We will respond to your request or inquiry within a reasonable period of time.

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19. NOT APPLICABLE IN CHINA. For clarity, this Privacy Policy does not apply to Ovention’s subsidiary website in China.

20. CONTACTING US. If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Data Controller:

Ovention Inc.
Attn: Marketing Leader
635 South 28th Street
Milwaukee, WI  53215
Phone:  414-615-2295
socialmedia@Oventionovens.com