Ingersoll-Rand plc ("Ingersoll-Rand") respects individual privacy and values the
confidence of its customers, employees, vendors, consumers, business partners and
others. Ingersoll Rand strives to collect, store, process and distribute Personal
information in a manner consistent with the laws of the countries in which it does
business, and has a tradition of upholding the highest ethical standards in its
business practices. Ingersoll Rand abides by the Safe Harbor Principles developed
by the U.S. Department of Commerce and the European Commission and the Frequently
Asked Questions (FAQs) issued by the Department of Commerce on July 21, 2000. This
principles that Ingersoll Rand follows with respect to transfers of Personal information
anywhere in the world, including transfers from the European Economic Area (EEA)
(which includes the twenty-seven member states of the European Union (EU) plus Iceland,
Liechtenstein and Norway) to the United States.
I. SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed
on a set of data protection principles and frequently asked questions (the "Safe
Harbor Principles") to enable US companies to satisfy the requirement under European
Union law that adequate protection be given to Personal information transferred
from the EU to the United States. The EEA also has recognized the US Safe Harbor
as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States
Department of Commerce and the Federal Data Protection and Information Commissioner
(FDPIC) of Switzerland have agreed on a similar set of principles and frequently
asked questions to enable U.S. companies to satisfy the requirement under Swiss
law that adequate protection be given to personal information transferred from Switzerland
to the United States (U.S.-Swiss Safe Harbor Framework). Consistent with its commitment
to protect personal privacy, Ingersoll Rand adheres to the Safe Harbor Principles
set forth in the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework.
Ingersoll Rand has a Global Data Protection Officer who assists in ensuring compliance
with this Policy and data security issues. Ingersoll Rand educates its employees
concerning compliance with this Policy and has self-assessment procedures in place
to assure compliance. Ingersoll Rand's Global Data Protection Officer Evan Turtz
and its Corporate Legal Team are available to any of its valued employees, customers,
vendors, business partners or others who may have questions concerning this Policy
or data security practices. Relevant contact information is provided herein.
This Policy applies to all Personal information received by Ingersoll Rand in any
format including electronic, paper or verbal. Ingersoll Rand collects, stores and
processes Personal information concerning current and former employees, as well
as applicants for employment through its Internet websites, its intranet site, electronic
mail and manually. Ingersoll Rand is the sole owner of information it collects,
stores and processes from current and former employees, applicants for employment,
customers, vendors and others. Ingersoll Rand will not sell or share this information
with third parties in ways different than what is disclosed in this Data Protection
Policy. On a global basis, Ingersoll Rand will, and will cause its affiliates to,
establish and maintain business procedures that are consistent with this Policy.
Notwithstanding the foregoing, Ingersoll-Rand has separate policies governing the
processing of employee personal data and external personal data in those countries
that are members of the European Union. These policies are consistent with the European
Directive 95/46/EC on the protection of personal data.
Personal information collected, stored and processed by Ingersoll Rand from employees
and applicants for employment is maintained at Corporate or at Regional HQ, depending
on the level of the position as well as the local office of the employee or applicant.
Ingersoll Rand collects Personal information for employment related purposes and
legitimate human resource business reasons such as recruitment and staffing; payroll
administration; absence monitoring; training and development; management planning;
appraisal and promotion; union negotiation; production and publication of company
address books and telephone and e-mail directories; production of employee Identity
cards; monitoring the use of company resources; information to contact close relatives
in case of emergency; filling employment positions; administration and operations
of its benefit and compensation programs; meeting governmental reporting requirements;
security, health and safety management; performance management; company network
access; and authentication. Ingersoll Rand does not request or gather information
regarding political opinions, religion, philosophy or sexual preference. To the
extent Ingersoll Rand maintains information on trade union membership, medical health,
race or ethnicity, Ingersoll Rand will protect, secure and process that information
in a manner consistent with this Policy and applicable law.
Personal information collected by Ingersoll Rand from prospective customers, consumers,
vendors, business partners and others may be maintained at its corporate offices
in Swords, Ireland, Davidson, North Carolina, Piscataway, New Jersey or at other
Ingersoll Rand facilities, consistent with local legislation. Ingersoll Rand collects
Personal information for, among other things, legitimate business reasons such as
customer service; product, warranty and claims administration; meeting governmental
reporting and records requirements; maintenance of accurate accounts payable and
receivable records; internal marketing research; safety and performance management;
financial and sales data; and contact information. All Personal information collected
by Ingersoll Rand will be used for legitimate business purposes consistent with
For purposes of this Policy, the following definitions shall apply:
"Agent" means any third party that processes Personal information provided by Ingersoll
Rand to perform tasks on behalf of or at the instruction of Ingersoll Rand.
"Ingersoll Rand" means Ingersoll-Rand plc., Inc., its subsidiaries, divisions and
groups, including, Climate Solutions, Industrial Technologies, Residential Solutions,
Security Technologies, with brands such as Thermo-King, Trane, Schlage, Club Car,
Interflex and Steelcraft.
"Personal information" means any information or set of information that identifies
or could be used by or on behalf of Ingersoll Rand to identify an individual. Personal
information does not include information that is encoded or anonymized, or publicly
available information that has not been combined with non-public Personal information.
"Sensitive Personal information" means Personal information that reveals race, ethnic
origin, trade union membership, political opinions, religious or philosophical beliefs
or that concerns health or sex life. In addition, Ingersoll Rand will treat as sensitive
Personal information any information received from a third party where that third
party treats and identifies the information as sensitive.
IV. PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the seven Safe Harbor Principles.
(1) NOTICE: Where Ingersoll Rand collects Personal information directly from individuals,
it will inform them about the purposes for which it collects, stores and processes
Personal information about them, the types of non-agent third parties to which Ingersoll
Rand discloses that information, and the choices and means, if any, Ingersoll Rand
offers individuals for limiting the use and disclosure of their Personal information.
Notice will be provided in clear and conspicuous language when individuals are first
asked to provide Personal information to Ingersoll Rand, or as soon as practicable
thereafter, and in any event before Ingersoll Rand uses the information for a purpose
other than that for which it was originally collected. Ingersoll Rand may disclose
Personal information if required to do so by law or to protect and defend the rights
or property of Ingersoll Rand.
(2) CHOICE: Ingersoll Rand will offer individuals the opportunity to choose (opt-out)
whether their Personal information is (a) to be disclosed to a non-agent 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.
For Sensitive Personal information, Ingersoll Rand will give individuals the opportunity
to affirmatively and explicitly (opt-in) consent to the disclosure of the information
to a non-agent third party or the use of the information for a purpose other than
the purpose for which it was originally collected or subsequently authorized by
Ingersoll Rand will provide individuals with reasonable mechanisms to exercise their
choices should requisite circumstances arise.
(3) DATA INTEGRITY: Ingersoll Rand will use Personal information only in ways that
are compatible with the purposes for which it was collected or subsequently authorized
by the individual. Ingersoll Rand will take reasonable steps to ensure that Personal
information is relevant to its intended use, accurate, complete and current.
(4) TRANSFERS TO AGENTS: Ingersoll Rand will obtain assurances from its Agents that
they will safeguard Personal information. Examples of appropriate assurances that
may be provided by Agents include: a contract obligating the Agent to provide at
least the same level of protection as is required by the relevant Safe Harbor Principles,
being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe
Harbor certification by the Agent, or being subject to another European Commission
adequacy finding (e.g., companies located in Switzerland). Where Ingersoll Rand
has knowledge that an Agent is using or disclosing Personal information in a manner
contrary to this Policy, Ingersoll Rand will take reasonable steps to prevent or
stop the use or disclosure. Ingersoll Rand holds it Agents accountable for maintaining
the trust our employees and customers place in the company.
(5) ACCESS AND CORRECTION: Upon request, Ingersoll Rand will grant individuals reasonable
access to Personal information that it holds about them. In addition, Ingersoll
Rand will take reasonable steps to permit individuals to correct, amend or delete
information that is demonstrated to be inaccurate or incomplete. Any employees that
desire to review or update their Personal information can do so by contacting their
local Human Resources Representative.
(6) SECURITY: Ingersoll Rand will take reasonable precautions to protect Personal
information in its possession from loss, misuse and unauthorized access, disclosure,
alteration and destruction. Ingersoll Rand protects data in many ways. Physical
security is designed to prevent unauthorized access to database equipment and hard
copies of sensitive Personal information. Electronic security measures continuously
monitor access to our servers and provide protection from hacking or other unauthorized
access from remote locations. This protection includes the use of firewalls, restricted
access and encryption technology. Ingersoll Rand limits access to Personal information
and data to those persons in Ingersoll Rand's organization, or as agents of Ingersoll
Rand, that have a specific business purpose for maintaining and processing such
Personal information and data. Individuals who have been granted access to Personal
information are aware of their responsibilities to protect the security, confidentiality
and integrity of that information and have been provided training and instruction
on how to do so.
(7) ENFORCEMENT: Ingersoll Rand will conduct compliance audits of its relevant privacy
practices to verify adherence to this Policy and the US Department of Commerce Safe
Harbor Principles. Any employee that Ingersoll Rand determines is in violation of
this Policy will be subject to disciplinary action up to and including termination
V. DISPUTE RESOLUTION
Any questions or concerns regarding the use or disclosure of Personal information
should be directed to the Ingersoll Rand Data Protection and Privacy Office at the
address given below. Ingersoll Rand 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. For complaints that cannot be resolved
between Ingersoll Rand and the complainant, Ingersoll Rand has agreed to participate
in the dispute resolution procedures of the panel established by the European Union
data protection authorities and to cooperate and comply with the Swiss Federal Data
Protection and Information Commissioner to resolve disputes pursuant to the Safe
VI. INTERNET PRIVACY
Ingersoll Rand sees the Internet, intranets and the use of other technologies as
valuable tools for communicating and interacting with consumers, employees, vendors,
business partners and others. Ingersoll Rand recognizes the importance of maintaining
the privacy of Personal information collected through websites that it operates.
Ingersoll Rand's sole purpose for operating its websites is to provide information
concerning products and services to the public. In general, visitors can reach Ingersoll
Rand on the Web without revealing any Personal information. Visitors on the Web
may elect to voluntarily provide Personal information via Ingersoll Rand websites
but are not required to do so. Ingersoll Rand collects information from visitors
to the websites who voluntarily provide Personal information by filling out and
submitting online questionnaires concerning feedback on the website, requesting
information on products or services, or seeking employment. The Personal information
voluntarily provided by website users is contact information limited to the user's
name, home and/or business address, phone numbers and email address. Ingersoll Rand
collects this information so it may answer questions and forward requested information.
Ingersoll Rand does not sell this information.
Ingersoll Rand may also collect anonymous information concerning website users through
the use of "cookies" in order to provide better customer service. "Cookies" are
small files that websites place on users' computers to identify the user and enhance
the website experience. Company personnel periodically audit Ingersoll-Rand’s commercial
websites to determine what cookies are used on each. The cookies used are typically
not intrusive and are not typically used to identify visitors personally. Visitors
may set their browsers to provide notice before they receive a cookie, giving the
opportunity to decide whether to accept the cookie. Visitors can also set their
browsers to turn off cookies. Visitors can learn how to control or delete cookies
used on Ingersoll-Rand’s websites by visiting http://www.aboutcookies.org for detailed guidance. If visitors
do suppress the website cookies, however, some areas of Ingersoll Rand websites
may not function properly.
The table below describes the cookies used on
www.Ingersollrand.com. To avoid these cookies, visitors can browse the website
using their browser’s anonymous usage setting (called "Incognito" in Chrome, "InPrivate"
for Internet Explorer, "Private Browsing" in Firefox and Safari.).
We use a session cookie that lasts for the duration of your visit to our site and
is used for load balancing.
User data is all anonymous.
Persistent Cookies for Site Analytics
Google Analytics – we use this to understand how the site is being used in
order to improve the user experience. User data is all anonymous.
You can find out more about Google’s position on privacy as regards its analytics
Adobe Site Catalyst - we use this to understand how the site is being used
in order to improve the user experience. User data is all anonymous.
You can find out more about Adobe’s position on privacy as regards its analytics
service at http://www.omniture.com/en/privacy/product
Few, if any, of Ingersoll Rand's websites are directed toward children. Nevertheless,
Ingersoll Rand is committed to complying with applicable laws and requirements,
such as the United States' Children's Online Privacy Protection Act ("COPPA").
Ingersoll Rand website users have the option to request that Ingersoll Rand not
use information previously provided, correct information previously provided, or
remove information previously provided to Ingersoll Rand. Those that would like
to correct or suppress information they have provided to Ingersoll Rand should forward
such inquiries to:
Ingersoll Rand Privacy Inquiries
80 Beaty Street, Building E
Davidson, North Carolina
Attention: Evan Turtz, Global Data Protection and Privacy Officer
The inquiries should include the individual's name, address, and other relevant
contact information (phone number, email address). Ingersoll Rand will use all reasonable
efforts to honor such requests as quickly as possible.
Ingersoll Rand websites may contain links to other "non-Ingersoll Rand" websites.
Ingersoll Rand assumes no responsibility for the content or the privacy policies
and practices on those websites. Ingersoll Rand encourages all users to read the
privacy statements of those sites; their privacy practices may differ from those
of Ingersoll Rand.
The practices described in this Policy are current Personal data protection policies
as of September 1, 2012. Ingersoll Rand reserves the right to modify or amend this
Policy at any time consistent with the requirements of the Safe Harbor Principles.
Appropriate notice will be given concerning such amendments.