Effective Date: July 17, 2025

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Overview and Scope

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We at Trew, LLC (the “Company,” “Trew,” “we,” “our,” or “us”) recognize the importance of protecting the privacy of personally identifiable information (“Personal Information” or “PII”) collected about you in connection with the operation of our business. We are committed to ensuring that your privacy is protected. To that end, this Privacy Policy (the “Policy”) discloses our practices regarding the collection, use, and disclosure of the PII we receive through your interactions with Trew. Unless otherwise expressly agreed to in writing, your Personal Information will be processed according to the terms of this Policy.

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This Policy applies when you: (i) interact with the our website, www.trewautomation.com, or any other sites, interactive services, applications, or platforms where this Policy appears or is linked (collectively, the “Site”), regardless of the medium by which the Site is accessed (e.g., via a web or mobile browser); or (ii) use our solutions or services (together with the Site, the “Services”).

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By using or otherwise engaging with our Services, you accept the terms of this Policy.

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Information We Collect

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We are the sole owner of information collected in connection with our Services. We collect several types of information from and about users of our Services, including:

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Personal Information: We may collect PII from you when you interact with the Services by, for example, registering for an account, completing forms, navigating web pages, filling out surveys, placing orders, or otherwise interacting with services, features, or resources we make available to you. PII means any information that is linked or reasonably linkable to an identified or identifiable natural person. PII does not include publicly available information from government records, deidentified or aggregate information, or information excluded from the scope of applicable laws.

 

The types of PII we have collected, used, stored, and disclosed in the last twelve (12) months include the following categories of information:

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• Identifiers

  • First name, last name, title, email, phone number, postal address, IP address, shipping information

• Financial Information

  • Bank routing information

• Categories of PII listed in the CA Consumer Customer Records law

  • First name, last name, address, phone number, bank routing information
    ​Information within this category may overlap with other categories.

• Commercial Information

  • Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

• Internet or Other Similar Network Activities

  • Browsing history, search history, interactions with the website, device activity

• Geolocation Data

  • Geolocation derived from your IP address
    You may disable our use of certain identifiers and activities through your device or browser settings.

 

Deidentified Information: We may collect deidentified information from you that may not by itself reasonably identify you as the source when you navigate the Services (“Deidentified Information”). Deidentified Information may include: (i) device type, (ii) device operating system, (iii) internet browser type, (iv) internet service provider, (v) referring/exit pages, (vi) date/time stamp, and (vii) clickstream information. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable and may not later be easily used to identify you as required by applicable law.

 

Children’s Information: We do not offer or promote our Services to, nor do we intentionally collect or retain PII from, children who are younger than 18 years of age. If we discover that we have inadvertently collected information from a child under 18 years of age, we will promptly take all reasonable measures to delete such information from our systems.

 

How We Collect Information

 

The information we collect depends on what you do when you visit the Site or utilize the Services. We collect PII and Deidentified Information in various ways, including:

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Directly from You: We collect PII when you voluntarily submit PII to us by completing forms on the Site, corresponding with us via phone, email, or other means, and in connection with other activities, services, features, or resources we make available in connection with our Services. The PII we collect depends on what you do when you visit the Site or utilize the Services and how you choose to communicate with us.

 

Through Your Use of the Site: We may collect PII and Deidentified Information that your browser transmits when you visit the Site or otherwise use the Services. We may also collect Deidentified Information about how you access and interact with the Services through the use of automated tracking technologies, such as session cookies, persistent cookies, and web beacons.

 

A cookie is a small data file that is transferred to an internet browser, which enables the Services to remember and customize your subsequent visits. We may use session cookies to make it easier for you to navigate the Services. Session cookies expire when you close your browser. We may also use persistent cookies to track and target your interests to enhance your experience in connection with the Services. Persistent cookies remain on your device for an extended period of time. 

 

Most internet browsers automatically accept cookies. However, you can instruct your internet browser to block cookies or to provide you with a warning prompt before you accept cookies from the Services. Please refer to your internet browser’s instructions to learn more about these functions. If you reject cookies, the functionality of the Services may be limited and you may not be able to participate in all of the Services’ features.

 

Additionally, we may use web beacons, which are single-pixel, electronic images embedded in the Services that allow us to gather information about your browsing activities.

 

From Third Parties: We may collect PII about you from individuals or other businesses that are subscribed to the Services, if they designate you as a user of the Services in connection with their subscription. We may also collect PII about you from various third parties that support our business operations, including payment and delivery services, event/trade-show organizers, and advertising and analytics providers. The privacy practices of these third parties may differ from the practices described in this Policy. We do not make any representations or warranties concerning, and will not in any way be liable for, any information, products, services, software, or other materials available through third parties. Your use of third parties’ services and/or third party websites is governed by and subject to the terms and conditions of those third parties and/or third party websites. We encourage you to carefully review the privacy policies and statements of such third parties and/or third party websites.

 

How We Use Information

 

We may use your PII for lawful business purposes to help enhance your experience. These purposes include:

 

Providing our Services: We may use your PII to fulfill the purpose for which you provide it in connection with the Services. For example, if you provide an email address when signing up for communications from Trew, we will use that email address to contact you as requested.

 

Fulfilling Orders: We may use your PII to process and ship orders for products that you place through the Services. For example, if you provide your mailing address in connection with a product order, we will use that mailing address to ship the product to you.

 

Direct Marketing: Subject to your preferences, we may use your PII to communicate with you about relevant services and offerings. For example, we might send promotional communications to you via email, phone, or standard mail. You have the right to opt-out of receiving direct marketing.

 

Customer Service and User Communications: We may use your PII to help us respond to your inquiries, questions, requests, and support needs more efficiently.

 

User Experience Personalization:  We may use your information to personalize the Services to your interests and preferences. For example, we may use your PII to tailor the content and information that we send or display to you, offer personalized recommendations, support, or instructions, or otherwise personalize your experience when using the Services. We may also use your PII and/or Deidentified Information in the aggregate to analyze the browsing and usage activities of our users in order to better understand their interests and preferences with respect to the Services. This will help us optimize your experience.

 

Business Optimization:  We may use your PII and/or Deidentified Information to improve the content on our web pages, customize the content and layout of our web pages, conduct internal research and development, administer surveys or conduct market research, identify opportunities to collaborate with you, or manage our everyday business needs. We may also use your feedback to improve our Services, including by monitoring, auditing, and analyzing trends, usage, and activities on and through the Services. All of this is done with the intention of making the Services more useful for you.

 

Safety and Security: We may use your PII and/or Deidentified Information to promote the safety and security of the Services, our users, and other parties. For example, we may use the information to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.

We will not collect additional categories of PII or use PII we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

How We Disclose Information

 

We may disclose your PII to certain third parties for a business purpose as described below. Otherwise, we do not sell, share, or rent PII and will not disclose your PII to third parties without your permission.

 

To Our Affiliates: We may disclose your PII to affiliates, including companies within the Trew group.

 

To Your Organization: If you access the Services through a subscription administered by your organization, we may disclose PII about you that is collected through your use of the Services with the administrators authorized by your organization in order to enable subscription management and other oversight functionalities.

 

To Service Providers and Contractors: We may disclose your PII to service providers and contractors that perform business functions on our behalf relating to the Services, including those that assist us in providing user support and troubleshooting services, processing payments, shipping and delivering orders, marketing and advertising our Services, communicating with users, and promoting our Services, or that otherwise perform business functions on our behalf relating to the Site and our services. If you opt-in to receiving text messages from or on behalf of us, we will never share that information with unaffiliated third parties.

 

To Advertising and Marketing Partners: We may disclose Deidentified Information to third-party advertising partners who help us serve advertisements across the web. This information does not identify you personally, but may be used by those marketing and advertising partners and other third parties to enable them to recognize you on other sites and services using their own cookies or similar technologies.

 

Law Enforcement, Safety, and Legal Processes:  We may disclose your PII to law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity.  We may also disclose your PII: (i) if required or permitted to do so by law; (ii) for fraud protection and credit risk reduction purposes; (iii) in the good-faith belief that such action is necessary to protect our rights, interests, or property; (iv) in the good-faith belief that such action is necessary to protect your safety or the safety of others; or (v) to comply with a judicial proceeding, court order, subpoena, or other similar legal or administrative process.

 

Sale or Acquisition of Assets:  If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your PII as part of the transaction. If the surviving entity in that transaction is not us, the surviving company may use your PII pursuant to its own privacy policies, and those policies may be different from this Policy.

 

As Disclosed or Consented To: We may disclose your PII for any other purpose disclosed by us at the time you provide that PII, or otherwise with your consent.

 

In the past twelve (12) months, we have disclosed the following categories of PII to third parties for a lawful business purpose: Identifiers; Financial Information; Categories of PII listed in the CA Consumer Customer Records Law; Commercial Information; Internet or Other Similar Network Activities; and Geolocation. We disclosed each of the foregoing categories of PII to our affiliates/business partners, service providers, government entities, and other third parties as described in this “How We Disclose Information” section of the Policy.

 

Security

 

The security and confidentiality of your PII is very important to us. We use commercially reasonable security measures to protect the PII you share with us through the Services. However, no data transmitted over or accessible through the internet can be guaranteed to be 100% secure.  As a result, while we attempt to protect your PII, we cannot guarantee or warrant that your PII will be completely secure (i) from misappropriation by hackers or from other nefarious or criminal activities, or (ii) in the event of a failure of computer hardware, software, or telecommunications networks.

 

Your Privacy Choices

 

We strive to provide you with choices regarding the PII you provide to us. We have created mechanisms to provide you with the following control over your PII:

 

Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts or functions of the Site may then be inaccessible or not function properly.

 

Promotional Communications: If you do not wish to receive promotional emails, text messages and/or other direct marketing communications from us, you may opt-out at any time by (i) following any instructions included in the communication; (ii) contacting us at privacy@trewautomation.com ; or (iii) making such changes through your user account. Please be aware that although you may opt-out of promotional emails, text messages and/or other direct marketing communications, we reserve the right to email you administrative notices regarding the Services and other non-promotional messages, as permitted under the CAN-SPAM Act. If you signed up to receive text messages or other push notifications from one of our service providers on our behalf and you wish to opt-out, you must opt-out directly through the relevant service provider.

 

Account Information: If you ever wish to access, update, change, delete, correct, or otherwise control your PII, you may do so by sending us an email with your request to privacy@trewautomation.com. To help us process your request, please provide sufficient information to allow us to identify you in our records. We reserve the right to ask for additional information verifying your identity prior to disclosing any PII to you. Should we ask for verification, the information you provide will be used only for verification purposes, and all copies of the information will be destroyed when the process is complete.

 

California Resident Rights

 

If you are a California resident, the CCPA grants you certain data privacy rights. Your rights include the:

• Right to Access: You have the right to request a copy of the specific pieces of PII that we have collected about you in the previous twelve (12) months. The information will be delivered by mail or electronically. Upon receipt of a Verifiable Consumer Request, we will disclose:

  • The categories of PII we have collected about you;

  • The categories of sources from which PII is collected;

  • Our business purpose for collecting PII;

  • The categories of third parties with whom we share PII, if any; and

  • The specific pieces of PII we have collected about you.

• Right to Data Portability: You have the right to receive your PII in a portable, readily usable format that allows you to transmit your information to another entity without hindrance.

• Right to Correct Inaccurate Information: You have the right to request that we correct inaccurate information about you that we maintain.

• Right to Deletion: You have the right request that we delete your PII.

• Right to Be Free from Discrimination: You have the right to not be discriminated against by us for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

  • Deny goods or services to you;

  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

  • Provide a different level or quality of goods or services to you; or

  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

 

In addition to the above, California’s “Shine the Light” law permits users of the Services that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes.

 

To exercise your rights, please use the Verifiable Consumer Request method described below. Please be aware that your rights (including those enumerated elsewhere in this Policy) are limited to the extent permitted by applicable law.

 

Other State Privacy Rights

 

Residents of certain other states may have additional personal information rights and choices, including rights related to advertising and analytics activities that may be considered “sales” or “sharing” of your PII or “targeted advertising” under the laws and/or regulations that apply to you. Depending on where you reside, you may have the right to opt out of targeted advertising, sharing, and sales of your PII, in addition to other applicable privacy rights. If you believe you have such additional rights and wish to exercise them, please contact us using the Verifiable Consumer Request method described below. Please be aware that your rights are limited to the extent permitted by applicable law and requests will be processed accordingly.

 

We will make commercially reasonable efforts to respond to opt-out requests and handle requests to access, update, change, delete, or otherwise control your PII as quickly as possible, as required by law.

 

Exercising Your Rights

 

You can exercise your state-specific legal rights by submitting a request (“Rights Request”) to us using one of the following methods:

• Calling us at + 1-513-548-0767 or +1-800-571-8739; or

• Emailing us at privacy@trewautomation.com .

 

Only you, or someone legally authorized to act on your behalf, may make a Rights Request related to your PII. Making a Rights Request does not require you to create an account with us. You may only make a Rights Request for access to PII twice in a 12-month period.

 

Your Rights Request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it including, without limitation, a description of the specific rights you wish to exercise.

 

We cannot respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm the PII relates to you. We will only use PII provided in a Rights Request to verify the requestor’s identity or authority to make the request.

 

We do not charge a fee to process or respond to Rights Request, unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

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Data Retention

 

We will retain your PII for as long as necessary to provide the Services and otherwise fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements.

 

Do Not Track Disclosure

 

Some internet browsers may transmit “do-not-track” signals to websites with which the browser communicates. The Services do not currently respond to these “do-not-track” signals.

 

SPAM

 

We do not participate in bulk email solicitations that you have not consented to receiving (SPAM). We do not sell or disclose customer lists or email address lists to unrelated third parties. Except as otherwise provided herein, we do not share PII with any third party advertisers.

 

Third Party Links

 

The Services may contain links to other websites or applications (“Linked Sites”) that are not owned by us.  We do not control the collection or use of any information, including PII, which occurs while you visit Linked Sites. Therefore, we make no representations or warranties for—and will not in any way be liable for—any content, products, services, software, or other materials available on Linked Sites, even if one or more pages of the Linked Sites are framed within the Services.

Furthermore, we make no representations or warranties about the privacy policies or practices of the Linked Sites, and we are not responsible for the privacy practices of those Linked Sites. We encourage you to be aware of when you leave the Services and read the privacy policies of Linked Sites.

 

Modifications

 

We reserve the right to update this Policy from time-to-time in our sole discretion. If our privacy practices change materially in the future, we will post an updated version of the privacy policy through the Services. It is your responsibility to review this Policy for any changes each time you use the Services. We will not lessen your rights under this Policy without your explicit consent. If you do not agree with the changes made, we will honor any opt-out requests made after the Effective Date of a new privacy policy.

 

Contact Information

 

If you have questions about the Policy or other questions or comments, please contact us at:

Trew, LLC

Attn: Privacy

10045 International Blvd.

West Chester, OH 45246

1-513-548-0767 or +1-800-571-8739

privacy@trewautomation.com

 

Effective Date

 

This Policy was last modified as of the effective date printed above. This version of the privacy policy replaces and supersedes any prior privacy policies applicable to the Services.