Privacy Statement

Arrowhead Winch Privacy Statement

May 2025

1. Introduction

   Arrowhead Winch Inc is committed to protecting your personal data. This privacy statement (the “Statement”) provides you with information regarding how we process your personal data including:

   • what personal data we collect from you,
   • for what purpose we use it,
   • what lawful basis we have to use it,
   • the categories of parties to whom we disclose it,
   • how we protect your personal data, and
   • what rights you have regarding your personal data.

   This privacy statement applies to personal data collected by Arrowhead Winch. If we collect and use your personal data in any context not covered by this Statement, we will give more specific information in addition to the information provided here..

   We may update portions of this Statement from time to time and will alert you that changes have been made by indicating on the Statement the date it was last updated. You can find the date of the last update at the top of the Statement. Keep in mind that your use of the Website (as defined below) and Arrowhead Winch’s services means that you accept the current version of this Statement as posted on the site at that time. We encourage you to re-visit this Statement on occasion to learn of any changes.

   If you have a disability which prevents you from electronically accessing this Statement and require it to be provided in an alternative format (for example, audio, large print), you can contact us using the information below.

2. How to Contact Us

   To contact Arrowhead Winch with any questions or requests pertaining to your personal data, you can utilize the following contact information:

   Arrowhead Winch Inc
   Marketing Department
   800 East Dallas Street
   Broken Arrow, OK 74012
   +1 (918) 251-8511
   marketing@arrowheadwinch.com

3. What personal data do we collect, and how do we use it?

   1. Website visitors and offline users

      Arrowhead Winch collects certain personal data from you if you visit our websites, use our apps, or if you interact with Arrowhead Winch in the other ways described below, including through in-person interactions at physical locations.

      Arrowhead Winch operates the Arrowhead Winch and NetServices websites and the Arrowhead Winch Publications Portal app (collectively, including all apps, the “Websites”). When you visit the Websites, we collect certain information about you.

      You may also choose to provide us with your personal data through sources other than the Websites. For example, if you sign up for communications or promotions, if you interact with us at trade shows, or if you attend an event that we host or sponsor.

      We also collect personal data when you apply for or express interest in a career opportunity with Arrowhead Winch.

      Arrowhead Winch collects information directly from you or, where applicable, your employer, automatically from your device, and from third party sources like directories or databases.

      The personal data that Arrowhead Winch collects from you, your employer, or third parties includes:

      • contact information such as name, address, e-mail address, and phone number
      • account information such as username, preferences and billing information
      • information about your company such as company name, company website, your title, and your role
      • type of phone provided (for example, work, home, mobile)
      • interests
      • recruiting information including education, work history, certifications and licenses, language skills, geographic preferences, references, salary expectations, information in documents you choose to provide such as a cover letter or curriculum vitae, and other information you may choose to provide such as your race or veteran status
      • images that you may choose to provide to us or otherwise make public via social media
      • any other information you may choose to provide at your discretion

      Arrowhead Winch uses this personal data for the following purposes:

      • to set up and maintain your account
      • to contact you with the communication you requested, such as when you make a query on a contact page on our website or a request for information
      • to understand your business and offer you potential business opportunities
      • to provide you with information and offers about Arrowhead Winch products and services and information resources
      • to better design, manage and enhance our products and services for you
      • to allow you to participate in promotional and marketing activities
      • to obtain leads and contacts
      • to send you surveys to allow you to participate in training opportunities
      • for market research, analytics, and business intelligence purposes

      The pseudonymous personal data that Arrowhead Winch collects automatically from the device(s) you use to access the Websites, some of which may be considered personal under applicable laws and regulation, includes:

      • IP address
      • device type
      • browser version
      • pages viewed
      • search history
      • operating systems
      • identifiers assigned to your device, such as cookies or mobile device advertising identifiers

      Arrowhead Winch uses this personal data for the following purposes:

      • to maintain and improve our website, to monitor our website’s performance and the use of our website and enhance your browser experience
      • to provide you with features and functionality

      We provide more information about cookies and describe the opt-out procedure in the Your choices and rights section below, and in our Cookie Statement.

   2. Business Partners (such as distributors, Original Equipment Manufacturers, suppliers, and other business third parties)

      If your employer is a business partner of Arrowhead Winch, we collect the following information about you:

      • contact information including name, address, telephone number, fax number, e-mail address
      • type of phone provided (for example, work, home, mobile)
      • information about your company such as company name, company website, company location, your title, and your role
      • government identifiers including social security numbers, driver’s license, passport numbers, and tax ID numbers
      • type of phone number provided (for example, work, home, mobile)
      • images of you that you voluntarily share with us on social media
      • financing information including credit reports, credit rating, financial statements, tax returns, references, and bank account or credit card number

      We use the information we collect for the following purposes:

      • to prepare and perform contracts for sale and delivery of products and services
      • to provide access to IT systems and web-portals
      • to assess creditworthiness and make credit determinations
      • to build and maintain relationships with you and your employer
      • to inform you about products and services that might be of interest to you
      • for market research, analytics, and business intelligence purposes
      • for participation in contests, sweepstakes, or other promotional activities
      • for the participation in surveys, training, and quality assessments
      • fulfilment of regulatory compliance

   3. Data from public sources

      Please be aware that we also collect data from public sources such as credit agencies, Chambers of Commerce, or other governmental institutions.

      In addition to the reasons set forth above, we may use any of your personal data we collect as we believe to be necessary or allowed:

      • under applicable law
      • to comply with legal process and our legal obligations
      • to respond to requests or requirements from public legal and governmental authorities (including national security and law enforcement requirements) and private parties
      • to enforce our terms and conditions
      • to protect our operations
      • to protect our rights, privacy, safety, or property, and/or that of you or others
      • to allow us to pursue available remedies or limit the damages that we may sustain and
      • to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical, or legally actionable activity

      We also may use and disclose information that does not identify you because it is in the form of aggregated or statistical data.

4. How long do we keep your personal data?

   Different retention periods apply for different types of personal data that we collect. We keep your personal data for as long as necessary:

   • for the purposes for which the information was collected
   • as business records reasonably retained in the normal course of business
   • to respond to any questions, complaints or claims that may be made by you or on your behalf
   • to keep records required by law

5. To whom do we disclose your personal data?

   We may disclose your personal data to the following categories of parties:

   • Arrowhead Winch related entities, subsidiaries, and affiliates, each of which are subject to this Statement
   • Our business partners such as:
     • vendors or service providers who help us provide our products and services and conduct our corporate business activities, including maintaining the Websites, supporting our marketing and other promotional activities, email management, and recruitment
     • distributors and suppliers
     • financial, tax, insurance, auditing, or legal advisors
     • marketing partners
   • Relevant Government departments and agencies

   We also may disclose your personal data when we reasonably believe it is required:

   • by law, subpoena, or other legal process
   • to protect or defend the rights of Arrowhead Winch property
   • to protect or defend the rights or property of Arrowhead Winch
   • to protect the health or personal safety of the public, or
   • in connection with the sale of all or part of our business or to honor user access rights, as applicable

   Additionally, we may transfer information to any other third party with your consent to do so.

   Arrowhead Winch does not sell your personal data to third parties.

   If our disclosure of personal data requires us to transfer your personal data outside of the EEA, UK, or Switzerland, we provide additional details on cross-border transfers in the section below International Transfer.

6. How do we protect your personal data?

   We care about protecting the availability, integrity, and accuracy of your personal data. Accordingly, we have implemented several security measures to help protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.

7. Your choices and rights

   You are not obligated to provide us your information. However, if the information is necessary to reply to your requests or answer your questions, we may not be able to assist you without it.

   You may opt out of promotional communications at any time by following the unsubscribe instructions included in the communications we send you. If you have any questions, you may contact us at marketing@arrowheadwinch.com.

   We use cookies on this website, which are small data files sent by websites to your hard drive through a web browser to enable the site to recognize your web browser, record activities, and ensure proper functionality of the website. If you wish to opt out of the use of cookies on the Website, you can find more details in Arrowhead Winch’s Cookie Statement. How to opt out depends on the type of browser and/or device you are using.

   If you wish to opt out of the use of cookies by third parties, you can do so either directly from their website or through an industry-developed web page. If you go to www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes.

   For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu.

8. Notification to users in the EEA, UK, or Switzerland

   Under the laws of the EEA, UK, and Switzerland, certain data we collect is considered “personal data.” We may have certain obligations and you may have certain rights with respect to this data.

   1. International transfer

      Arrowhead Winch is a global company with headquarters in the United States.

      Under the European General Data Protection Regulation (GDPR) or equivalent laws, some countries may be deemed to not provide an adequate level of data protection for your personal data. When we transfer personal data outside of the EEA, UK, or Switzerland, we ensure that appropriate protections are in place. These protections may include a legal mechanism such as the standard contractual clauses approved by the European Commission, which helps to ensure that the parties to whom we disclose your personal data uphold the same or similar standards of data protection as Arrowhead Winch.

   2. Role of company as a controller or processor

      If you are located in the EEA, UK, or Switzerland, Arrowhead Winch may act as the controller as defined under applicable law when processing personal data.

   3. Legal basis for processing

      Arrowhead Winch’s legal basis for processing your personal data depends upon the specific context in which we collect or use it. In many cases, we will process your personal data based on our legitimate interests. These legitimate interests include operating our websites, managing our recruitment and marketing efforts, and providing our products and services. You have a right to object to processing on the basis of legitimate interests.

      If consent is the legal basis, for example in certain situations when we send you marketing communications, we will obtain your consent and let you know how you can withdraw your consent.

      Our other legal bases for processing include contractual and legal obligations.

   4. Your rights

      Users in the EEA, UK, and Switzerland may have certain rights related to their personal data. This includes the right to access, correct and receive a copy of your personal data, the right to deletion of your personal data, the right to data portability, the right to restrict the processing of your personal data, the right to object or withdraw consent to the processing of your personal data, and the right to lodge a complaint with a regulatory authority. If you are a user in the EEA, UK, or Switzerland and have questions regarding how to exercise your rights with Arrowhead Winch or wish to submit a request, please contact marketing@arrowheadwinch.com.

9. Notification to California residents

   The California Consumer Privacy Act or “CCPA” applies to the collection, use, and disclosure of “personal information” collected from California residents (as those terms are defined by the CCPA).

   If you are a California resident, the CCPA requires us to disclose to you the categories of personal information we collect, our business and commercial purposes for collecting, using, sharing, or selling such personal information, the categories of sources from which we collect personal information, the categories of personal information we have disclosed, shared, or sold for a business or commercial purpose in the preceding 12 months, and the categories of third parties with whom we share personal information. We have provided these disclosures in this Statement, and below are additional details.

   In the preceding twelve (12) months, the personal information that Arrowhead Winch has collected, which we describe in more detail above in the section What personal data do we collect, and how do we use it, fall into the following categories under the CCPA:

   • identifiers
   • personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
   • protected classification characteristics under California or federal law
   • commercial information
   • internet or other similar network activity
   • geolocation data
   • sensory data (e.g., visual images or audio recordings shared via social media)
   • professional or employment-related information
   • inferences drawn from other personal information

   Arrowhead Winch may have collected the following categories of sensitive information in the preceding twelve (12) months:

   • social security, driver’s license, state identification card, or passport number
   • precise geolocation information
   • racial or ethnic origin, or union membership
   • personal information concerning health
   • personal information concerning sex life or sexual orientation

   Arrowhead Winch obtains the personal information listed above from the following categories of sources:

   • directly from you
   • directly and indirectly from dealers, distributors, suppliers, other third parties, and customers or their agents
   • directly and indirectly from activity on the Websites
   • from third parties and business partners that interact with Arrowhead Winch and its affiliates and subsidiaries in connection with the services we perform

   In the preceding twelve (12) months, Arrowhead Winch has disclosed the following categories of personal information for a business purpose:

   • identifiers
   • personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
   • protected classification characteristics under California or federal law
   • commercial information
   • internet or other similar network activity
   • geolocation data
   • sensory data (e.g., visual images or audio recordings shared via social media)
   • professional or employment-related information
   • inferences drawn from other personal information

   We disclose personal information for business purposes to the following categories of third parties:

   • our affiliates and subsidiaries
   • service providers
   • third parties to whom you or your agents authorized us to disclose personal information in connection with products or services we provide to you

   In the preceding twelve (12) months, we have not sold any personal information, including sensitive personal information.

   Arrowhead Winch does not disclose your personal information to third parties for the purpose of cross-context behavioral advertising, but you may see Arrowhead Winch ads on third party websites and applications. Arrowhead Winch, however, has not shared, as that term is defined in the CCPA, your personal information including sensitive personal information with these or other parties in the preceding twelve (12) months.

   1. Your rights and choices under the CCPA

      Under the CCPA, you or an authorized agent acting on your behalf, may have the right to: (i) know information regarding the personal information Arrowhead Winch collects and request access to your personal information, (ii) know what personal information Arrowhead Winch sells or shares and to whom, (iii) request deletion of your personal information, (iv) request correction of inaccurate personal information, (v) opt out of the “sale” and/or “sharing” of your personal information (as those terms are defined by the CCPA), and (vi) not be discriminated against for opting out or exercising any of your rights under the CCPA. If you submit a request, we may ask you to provide certain information to compare against our records to verify your identity and respond to your requests. We will endeavor to respond to your requests within forty-five (45) days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know. You may submit a request under the CCPA by:

      • contacting the Marketing Department at 1 (918) 251-8511
      • emailing the Marketing Department at marketing@arrowheadwinch.com, or
      • submitting a letter to the address provided in the Contact Information section

   2. Non-discrimination

      We will not discriminate against you for exercising any of your CCPA rights.

   3. Users under 16 years old

      Arrowhead Winch does not knowingly collect or sell any information from or about children under the age of sixteen. If you believe that we have received information of a child, please contact us at marketing@arrowheadwinch.com.

   4. Links to other websites

      This Statement applies to our websites, corporate activities, and products and services. As a convenience to you, each website may contain links to other sites that may provide useful information or link with other platforms. Arrowhead Winch does not control these third-party sites and is not responsible for their privacy practices or content. You should refer to the privacy statements of such third-party sites to find out how they collect and use your information.