Trane Leasing, Inc. ("Trane
") respects individual privacy and values the
confidence of its customers, employees, vendors,
consumers, business partners and others. Trane
strives to collect, use and disclose 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.
Trane 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 Safe Harbor Privacy Policy (the "Policy")
sets forth the privacy principles that Trane
follows with respect to transfers of Personal information
anywhere in the world, including transfers from the
European Economic Area (EEA) (which includes the fifteen
member states of the European Union (EU) plus Iceland,
Liechtenstein and Norway) to the United States.
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). Consistent
with its commitment to protect Personal privacy, Trane
adheres to the Safe Harbor Principles.
Trane has a Chief Privacy Officer who is
responsible for Trane's compliance with and
enforcement of this Policy. Trane also has a
Global Director of Data Protection who assists in ensuring
compliance with this Policy and data security issues.
Trane educates its employees concerning
compliance with this Policy and has self-assessment
procedures in place to assure compliance.
Trane's Chief Privacy Officer Barbara A. Sellinger,
Global Director of Data Protection Hugh C. Welsh, and
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 Trane in any format including
electronic, paper or verbal. Trane collects
and processes Personal information concerning current and
former employees and their respective family members, as
well as applicants for employment through its Internet
websites, its intranet site, electronic mail and manually.
Trane is the sole owner of information it
collects from current and former employees, applicants for
employment, customers, vendors and others.
Trane will not sell or share this information with
third parties in ways different than what are disclosed in
this Privacy Policy. On a global basis, Trane
will, and will cause its affiliates to, establish and
maintain business procedures that are consistent with this
Policy.
Personal information collected by Trane
from employees and applicants for employment is maintained
at its corporate offices in Piscataway, New Jersey in the
United States as well as the local office of the employee
or applicant. Trane collects Personal
information for, among other things, legitimate human
resource business reasons such as payroll administration,
to fill employment positions, maintaining accurate
benefits records, meeting governmental reporting
requirements, security, health and safety management,
performance management, company network access and
authentication. Trane does not request or
gather information regarding political opinions, religion,
philosophy or sexual preference. To the extent
Trane maintains information on an individual’s
medical health or ethnicity (as legally required)
Trane will protect, secure and use that information
consistent with this Policy.
Personal information collected by Trane
from prospective customers, consumers, vendors, business
partners and others may be maintained at its corporate
offices in Piscataway, New Jersey or at other
Trane facilities. Trane 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 Trane will be used
for legitimate business purposes consistent with this
Policy.
For purposes of this Policy, the following definitions
shall apply:
"Agent" means any third party that uses
Personal information provided by Trane to
perform tasks on behalf of or at the instruction of
Trane.
"Trane" means Trane
Leasing, Inc., its predecessors, successors,
subsidiaries, divisions and groups.
"Personal information" means any information
or set of information that identifies or could be used by
or on behalf of Trane 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, or that concerns health. In
addition, Trane will treat as sensitive
Personal information any information received from a third
party where that third party treats and identifies the
information as sensitive.
The privacy principles in this Policy are based on the
seven Safe Harbor Principles.
(1) NOTICE: Where Trane collects Personal
information directly from individuals, it will inform them
about the purposes for which it collects and uses Personal
information about them, the types of non-agent third
parties to which Trane discloses that
information, and the choices and means, if any,
Trane 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 Trane, or as soon as
practicable thereafter, and in any event before
Trane uses the information for a purpose other than
that for which it was originally collected.
Trane may disclose Personal information if required to
do so by law or to protect and defend the rights or
property of Trane.
(2) CHOICE: Trane 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, Trane
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
the individual.
Trane will provide individuals with
reasonable mechanisms to exercise their choices should
requisite circumstances arise.
(3) DATA INTEGRITY: Trane will use Personal
information only in ways that are compatible with the
purposes for which it was collected or subsequently
authorized by the individual. Trane will take
reasonable steps to ensure that Personal information is
relevant to its intended use, accurate, complete, and
current.
(4) TRANSFERS TO AGENTS: Trane will obtain
assurances from its Agents that they will safeguard
Personal information consistently with this Policy.
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 Hungary and Switzerland). Where
Trane has knowledge that an Agent is using or
disclosing Personal information in a manner contrary to
this Policy, Trane will take reasonable steps
to prevent or stop the use or disclosure.
Trane holds its Agents accountable for maintaining the
trust our employees and customers place in the company.
(5) ACCESS AND CORRECTION: Upon request,
Trane will grant individuals reasonable access to
Personal information that it holds about them. In
addition, Trane will take reasonable steps to
permit individuals to correct, amend, or delete
information that is demonstrated to be inaccurate or
incomplete. Any employee that desires to review or update
their Personal information can do so by contacting their
local Human Resources Representative.
(6) SECURITY: Trane will take reasonable
precautions to protect Personal information in its
possession from loss, misuse and unauthorized access,
disclosure, alteration and destruction. Trane
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. Trane limits access to
Personal information and data to those persons in
Trane's organization, or as agents of
Trane, 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: Trane 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
Trane determines is in violation of this
policy will be subject to disciplinary action up to and
including termination of employment.
Any questions or concerns regarding the use or
disclosure of Personal information should be directed to
the Trane Privacy Office at the address given
below. Trane 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 Trane and the
complainant, Trane has agreed to participate
in the dispute resolution procedures of the panel
established by the European data protection authorities to
resolve disputes pursuant to the Safe Harbor Principles.
Trane 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. Trane
recognizes the importance of maintaining the privacy of
Personal information collected through websites that it
operates. Trane's sole purpose for operating
its websites is to provide information concerning products
and services to the public. In general, visitors can reach
Trane on the Web without revealing any
Personal information. Visitors on the Web may elect to
voluntarily provide Personal information via
Trane websites but are not required to do so.
Trane collects information from visitors to the
websites who voluntarily provide Personal information by
filing out and submitting on-line 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.
Trane collects this information so that it may
answer questions and forward requested information.
Trane does not sell or share this information
with non-agent third parties.
Trane 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. None of this information is
reviewed at an individual level. Visitors may set their
browsers to provide notice before they receive a cookie,
giving them opportunity to decide whether to accept the
cookie. A visitor can also set their browser to turn off
cookies. If visitors do so, however, some areas of
Trane websites may not function properly.
Few, if any, of Trane's websites are
directed toward children. Nevertheless, Trane
is committed to complying with applicable laws and
requirements, such as the United States' Children's Online
Privacy Protection Act ("COPPA").
Trane website users have the option to
request that Trane not use information
previously provided, correct information previously
provided, or remove information previously provided to
Trane. Those that would like to correct or
suppress information they have provided to
Trane should forward such inquiries to:
One Centennial Avenue
Piscataway, New Jersey
08855-6820
Attention: Hugh C. Welsh, Global Director of Data
Protection
The inquiries should include the individual's name,
address, and other relevant contact information (phone
number, email address). Trane will use all
reasonable efforts to honor such requests as quickly as
possible.
Trane websites may contain links to other
"non-Trane" websites.
Trane assumes no responsibility for the content or the
privacy policies and practices on those websites.
Trane encourages all users to read the privacy
statements of those sites; their privacy practices may
differ from those of Trane.
The practices described in this Policy are current
Personal data protection policies as of December 31, 2001.
Trane reserves the right to modify or amend
this Policy at any time consistent with the requirements
of the Safe Harbor Principles. Appropriate public notice
will be given concerning such amendments.
