The FEUER powertrain Group is a leading OEM independent manufacturer of cast and forged crankshafts for passenger car, industrial motor, ATV and agricultural machinery applications. FEUER powertrain was established in 2002 in Nordhausen, Thuringia (Germany) and today operates production plants in Germany and the US as well as an assembly plant in China, with a combined annual capacity of up to 2.5 million crankshafts.

FEUER powertrain North America, Inc., located in Robinsonville, Mississippi (just south of Memphis, TN), was opened in 2016.  The state-of-the-art, climate-controlled facility is fully automated and designed to foster innovation and advanced manufacturing processes.  The primary ambition of the US subsidiary was to enhance the FEUER Group’s global manufacturing footprint and provide a cost, logistic and service advantage to our North and South American customers.  After an investment of about $68 million to date in the 143,000-square-foot plant in Tunica County, the company plans to see a second full production line, additional buildings and a total investment of about $140 million within the next five years.  Our long-term goal will include an increase of the workforce to 300 employees.

FEUER powertrain North America, Inc. is a privately-owned organization, free of corporate politics and bureaucracy.  We are not interested in red tape, fixed mindsets, low expectations, or blending in.  We are interested in solution seekers, ethical decision-makers, communicators, creative thinkers, collaborators, and innovators.  We are an inclusive organization that believes in a transparent working environment and an open-door policy.

We are huge believers in promoting from within as the personal and professional growth of our workforce is always a top priority.  We offer a family-oriented working environment and our employees are hardworking, easy going, and down-to-earth.  Our managers expect excellence, but they are flexible, understanding, and fair. 

We are continuously transforming the way we operate to improve our ability to innovate, expand, and keep our customers satisfied.  Just as a crankshaft is the heart of a vehicle, our employees are the heart of our organization.

“To be North America’s leading crankshaft supplier through advanced manufacturing, quality excellence, and customer satisfaction.”

FEUER powertrain North America, Inc. respects individuals’ privacy, and strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business. This Privacy Shield Privacy Policy describes the privacy principles as follows with respect to certain personal information transmitted to FEUER powertrain North America, Inc. from countries located within the European Union.

1. PRIVACY SHIELD OVERVIEW

The U.S. Department of Commerce and the European Commission have agreed on a set of data protection principles and associated supplemental principles to enable U.S. companies to satisfy European Union (“EU”) law, requiring that Personal Data transferred from the EU to the U.S. be adequately protected (the “EU-U.S. Privacy Shield” , the “Privacy Shield”).

FEUER powertrain North America, Inc. (“FPTNA”) has adopted this Privacy Shield Policy ("Policy") to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that FPTNA obtains from customers and suppliers located in the European Union.

FPTNA complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. FPTNA has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

2. SCOPE

This Policy applies to all Personal Data received by FPTNA in the United States from the EU, either directly from individuals, from its affiliates or from other third party organizations, and in any format whatsoever, including electronic, paper or oral transmission. This Policy also applies to FPTNA’s Agents (defined below) that process Personal Data received by FPTNA in the United States from the EU on behalf of FPTNA.

3. DEFINITIONS

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

 “Personal Data” and “Personal Information” means data about an identified or identifiable individual that are within the scope of the Privacy Shield, received by an organization in the United States from the European Union, and recorded in any form. Personal Data includes all Sensitive Personal Data (as defined below).

 “Sensitive Personal Data” or “Sensitive Personal Information” means personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual or, where received from a third party, data that is identified and treated as sensitive by the third party. This can also include ideological views or activities, and information on social security measures or administrative or criminal proceedings and sanctions, which are treated outside pending proceedings.

  “Processing” of personal data means any operation or set of operations which is performed upon personal data, whether or not by automated means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure or dissemination, and erasure or destruction.

 “Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of personal data.

 “Agent” means any third party that collects or uses Personal Data provided by FPTNA to perform tasks on behalf of FPTNA under the instructions of, and solely for, FPTNA.

 “FPTNA” “we” “our” or “us” means FEUER powertrain North America, Inc. and its successors, assigns and wholly-owned affiliates and their respective divisions and groups, each of which are located within the U.S.

4. PRIVACY PRINCIPLES FOR PROCESSING OF PERSONAL DATA RECEIVED FROM THE EU

 The privacy principles set forth in this Policy have been developed based on the Privacy Shield Principles.

4.1 NOTICE

Where FPTNA collects Personal Data directly from individuals in the EU or receives it from its European parent company, it or its European parent company will inform those individuals about the purposes for which they collect and use Personal Data about them; the transfer of Personal Data to FPTNA in the U.S., the types or identity of third parties to which FPTNA discloses that information and the purposes for which it does so; and the choices and means FPTNA offers individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Data to FPTNA, or as soon as practicable thereafter, and in any event before FPTNA uses the information for a purpose other than that for which it was originally collected. FPTNA may from time to time process certain Personal Data about customers, business partners, suppliers, vendors, service providers, employees and candidates for employment, including information recorded and stored on various types of media, including electronic media. FPTNA will process these types of data in conformity with the Privacy Shield Principles and will continue to apply the Principles to personal data received under the application of the Privacy Shield as long as it holds this data.

Purposes for which we may collect and use Personal Data from our customers, consumers and other non-employees include:

• Communicating to individuals about our products, services and related issues.

· Improving our site and notify individuals about updates to our site.

• Notifying individuals of, and administering, contests, sweepstakes, promotions and other offers.

• Evaluating the quality of our products and services.

• Transferring Personal Data in connection with FPTNA’s legal, regulatory compliance and auditing purposes.

• Facilitating FPTNA’s internal administrative purposes and application functionality, maintaining, administering and complying with FPTNA’s legal, regulatory compliance and auditing obligations, policies and procedures.

• Execution of contracts and delivery of products and services to customers; execution and management of development, engineering and construction projects; manufacturing execution and supply chain management.

 FPTNA also collects Personal Data concerning its employees and candidates for employment (Human Resources Data) in connection with administration of its human resources programs and functions and for purpose of communicating with its employees.

 We may share Personal Data with the parent company FEUER powertrain GmbH & Co. KG located in Germany. FPTNA may also share Personal Data with its third party Agents for the sole purpose of, and only to the extent needed to, support FPTNA’s or our customers’ business needs. We may also disclose Personal Data to our Agents in the U.S. and other third parties when required to do so under law or by legal process. Third Party Agents are required to keep confidential Personal Data received from FPTNA and may not use it for any purpose other than originally intended.

4.2 CHOICE

FPTNA will offer individuals in the EU the opportunity to choose (by either opt-out or opt-in) if their Personal Data is (a) to be disclosed to a third party that is not an Agent, or (b) to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by the individual.

For Sensitive Personal Data, FPTNA will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to permit FPTNA to (a) disclose their Sensitive Personal Data to a third party that is not an Agent or (b) use Sensitive Personal Data for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by the individual.

FPTNA will provide individuals with reasonable, clear and conspicuous and readily available mechanisms to exercise these choices.

4.3 ACCOUNTABILTY FOR ONWARD TRANSFER

FPTNA will transfer Personal Data to Agents only for limited and specific purposes. FPTNA will obtain contractual assurances from its Agents that they will safeguard Personal Data in a manner consistent with this Policy and that they will provide at least the same level of protection as is required by the relevant Privacy Shield Principles. FPTNA recognizes its responsibility and potential liability for onward transfers to Agents. Where FPTNA has knowledge that an Agent is using or disclosing Personal Data in a manner contrary to this Policy and/or the level of protection as required by the Privacy Shield Principles, FPTNA will take reasonable steps to prevent, remediate or stop such use or disclosure.

If FPTNA transfers Personal Information to non-agent third parties acting as a Controller, FPTNA will apply the notice and choice principles and will obtain contractual assurance from these parties that they will provide the same level of protection as is required under the principles, unless a derogation for specific situations under European data protection law applies.

4.4 ACCESS

Upon request and in accordance with the Privacy Shield Principles, FPTNA will grant individuals reasonable access to their Personal Data that is held by FPTNA. In addition, FPTNA will take reasonable steps to permit individuals to correct, amend, or delete their Personal Data that is demonstrated to be inaccurate, incomplete or processed in violation of the Privacy Shield Principles. In accordance with the Privacy Shield Principles, FPTNA may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy, where the legitimate rights of persons other than the individual would be violated or if necessary to safeguard important countervailing public interests (e.g., national security) or in other limited circumstances (e.g., disclosure would breach a legal or other professional privilege).

4.5 SECURITY

FPTNA will take reasonable precautions to protect Personal Data in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data.

4.6 DATA INTEGRITY AND PURPOSE LIMITATION

FPTNA will use Personal Data only in ways that are compatible with the purposes for which it was originally collected or as subsequently authorized by the individual. FPTNA will also take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. FPTNA will adhere to the Privacy Shield Principles for as long it retains Personal Information received under its Privacy Shield certification.

4.7 RECOURSE, ENFORCEMENT AND LIABILITY

FPTNA utilizes the self-assessment approach to verify its compliance with this Policy. FPTNA periodically verifies that this Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Privacy Shield Principles. FPTNA will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with the Privacy Shield Principles. FPTNA will also investigate suspected infractions of this Policy. If FPTNA determines that any employee of FPTNA is in violation of this Policy, such person will be subject to disciplinary action up to and possibly including termination of employment.

FPTNA encourages interested persons with questions or concerns relating to this Policy to contact us using the contact information below. Any questions or concerns regarding the use or disclosure of Personal Data should be directed to the HR Department at the address set forth below.

With respect to any complaints relating to this Policy that cannot be resolved through FPTNA’s internal processes, FPTNA has agreed to cooperate with the European data protection authorities and to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Privacy Shield Principles. FPTNA is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC), which is the competent supervisory authority under the Privacy Shield.

Where a complaint cannot be resolved by any of the before mentioned recourse mechanisms, individuals have a right to invoke binding arbitration under the Privacy Shield Panel as a recourse mechanism of ’last resort’.

In the event that FPTNA or such authorities determines that FPTNA failed to comply with this Policy, FPTNA will take appropriate steps to address any adverse effects arising directly from such failure and to promote future compliance.

5. LIMITATIONS

FPTNA’s adherence to the Privacy Shield Principles may be limited (a) to the extent necessary to meet applicable national security, public interest, or law enforcement requirements, e.g. in the course of lawful requests by public authorities (b) by statute, government regulation, or case law that creates conflicting obligations or explicit authorizations, provided that, in exercising any such authorization, an organization can demonstrate that its non-compliance with the principles is limited to the extent necessary to meet the overriding legitimate interests furthered by such authorization; or (c) if the effect of the Directive or Member State law is to allow exceptions or derogations, provided such exceptions or derogations are applied in comparable contexts.

6. CONTACT INFORMATION

Questions or comments regarding this Policy or our practices concerning Personal Data should be submitted to FPTNA’s HR department by mail or e-mail as follows:

FEUER powertrain North America, Inc. 2130 Casino Center Drive Extended, MS-38664 Robinsonville, USA

e-mail: info@feuer-usa.com

7. CHANGES TO THIS POLICY

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield Principles. Appropriate public notice will be given concerning such amendments.

8. EFFECTIVE DATE

This Policy is effective as of: 16th August 2018