Privacy Policy and Information Notice

Thank you for visiting the Ducommun website ("Site"). Ducommun and its subsidiaries and affiliates ("Ducommun", "we", "us", "our") are committed to treating the personal and corporate information of our Site users, customers and vendors with respect and sensitivity. This Privacy Policy describes the types of information we collect, how we use the information, whether we share the information with anyone else and if so with whom, and how you may contact us about our privacy policy.

If you are a California resident, our privacy practices comply with the California Consumer Privacy Act of 2018 ("CCPA"), and any CCPA-specific information is identified in this Policy. Explanation of your rights under the CCPA can be found here.

If you are a resident of the European Economic Area ("EEA"), this Privacy Policy also outlines additional policies applicable to our collection and processing of your personal information, which can be found here.

As our services evolve and we perceive the need or desirability of using your Personal Information collected in other ways, we may from time to time amend this Privacy Policy. The effective date appears at the end of this Privacy Policy. We encourage you to check our Site frequently to review the current Privacy Policy in effect and any changes that may have been made to it.

By providing your Personal Information to us in any format (e.g., via email, telephone, fax, or in person) and/or continuing to use any of our services or visiting our Site you accept and consent to the practices described in this Privacy Policy and Information Notice.

Click on one of the links below to jump to the listed section:

Definitions
What Personal Information does the Company collect?
How does the company use Personal Information?
Do we share your Personal Information with any third parties?
Where we store your Personal Information
How we protect your Personal Information
How long we store your Personal Information
Additional Policies in Compliance with the CCPA
Additional Policies in Compliance with the EEA Privacy Laws
Access to your Personal Information
Protecting Children's Privacy
Links to other websites
Changes to our Privacy Policy and Contacting Us

1. Definitions

The following definitions apply to this Privacy Policy:

"Personal Information" means information (whether stored electronically or in paper based filing systems) relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal Information comprises the categories of Personal Information defined by the CCPA.

Identifiers

Name, address, email, phone, SSN, driver's license

Other Data

Financial information, medical information, health insurance information

Protected Classes

Race, gender, sexual orientation, religion, citizenship

Commercial Information

Records of personal property, purchasing or consuming histories or tendencies

Internet Activity

Browsing history, search history, IP address, website interactions

Sensory Data

Audio, electronic, visual, thermal, olfactory

Professional Data

CV, resume, employment history

"Processing" is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.

1 The examples given in this table are not meant to provide an exhaustive list but are examples of the kinds of data included in each category. The Company does not collect Personal Information in every one of these categories, and we identify below which categories of information we do collect. Personal Information under the CCPA also includes any other category of personal information not included within the CCPA's definition that are defined in California Civil Code § 1798.80(e). We refer to this category as "Other Data," and it includes information such as financial information (bank account number, credit card number, debit card number), medical information, health insurance information, and insurance policy number.

2. What Personal Information does the company collect?

When you contact us through our Site, or by corresponding with us by phone, e-mail, or otherwise, we may collect Personal Information including:

2.1      Personal Information Collected about Customers or Vendors

In order to provide our clients with individualized services, we collect certain non-public, personal information about you from documents you provide to us, such as your tax returns, your contracts, and your bank and investment account statements. In addition to receiving personal information directly from you, we may also receive information from your attorney, bank, securities broker, other investment advisers, and other sources. We will only obtain such information from third parties with your express consent, as permitted by law.

We may collect the following categories of Personal Information from our clients:

  • Identifiers: name, address, email, phone, social security number, federal tax ID number, passport, driver's license, or other relevant identifiers, as applicable.

  • Other Data (§ 1798.80): Financial information such as credit card and account numbers; financial records, such as tax information, securities filings, etc.; medical and health records and data as necessary, including health insurance accounts and records.

  • Protected Classes: gender, race, sexual orientation, and citizenship information, as necessary.

  • Professional Data: we may occasionally collect professional data such as C.V., salary history, and education history, as necessary.

  • Sensory Data: we employ video surveillance at certain of our facilities for security purposes.

When considering an individual for employment, additional Personal Data may be collected, as set forth in our Employee Privacy Policy.

2.2      Information we collect automatically about website visitors

When you visit our Site, our web server automatically collects the following Internet Activity:

  • Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), pages on our Site you viewed; page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
2.3      Information we receive from other sources

This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this Site. We will also have told you for what purpose we will share and combine your data. We are working closely with third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

2.4      Cookies

A cookie is a text file that our Site transfers to your computer's hard drive for record-keeping purposes and to enhance the quality of your visit to our Site. We use cookies to personalize our Site for you and to collect aggregate information about the Site usage by all of our users.

Cookies enable us to identify your device. We use cookies that are strictly necessary to enable you to move around the site or to provide certain basic features. We use cookies to enhance the functionality of the website by storing your preferences, for example. We also use cookies to help us to improve the performance of our website to provide you with a better user experience. By using this Site and/or accepting cookies (e.g., where you are notified that they are intended to be used and you accept their use), they will be placed to maximize your experience and to help us understand how we can improve our Site.

Like many websites, we do not currently respond to "do not track" browser headers. But with most internet browsers, you can take steps to limit the use of cookies. If you do not want us to use cookies in your browser, you can remove cookies from your computer's hard drive, or set your browser to block cookies or to send a warning notice before a cookie is stored on your computer. However, please note that you may not be able to use many of the services on our website or other websites without cookies.

The cookies we may use on this Site are:

Cookies

Purpose

Google Analytics

These cookies are used to collect information about how visitors use the Site.  We use this information to compile reports and to help us improve the Site.  The cookies collect information in an anonymous form, including the number of visitors to the Site, where visitors have come to the Site from and the pages they visited.  To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

More detailed information on cookies can be found at www.allaboutcookies.org.

3. How does the Company use Personal Information?

We use information held about you in the following ways:

3.1    Information you give to us.  We will use this information:  

  • To provide you with the information, products, and services that you request from us;

  • To send you direct marketing and promotional materials, or other communications;

  • To respond to requests for information, services, or email notifications, or to respond to other enquiries;

  • For training purposes, quality assurance, and to record details about the products and services you order from us;

  • To comply with applicable laws and regulations;

  • To carry out our obligations arising from any contracts entered into between you and us, or between you and our vendors or distributors;

  • To provide you with information about other goods and services we offer, or that are offered by our affiliates or third party vendors, that are similar to those that you have already purchased or enquired about;

  • To notify you about changes to our service;

  • To make inquiries about you for credit reference purposes;

  • To perform data analyses (including anonymization and aggregation of Personal Data);

  • For prospective employees, to respond to your job application and process your CV.

3.2    Information we collect automatically. We will use this information:

  • To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;

  • To improve our site to ensure that content is presented in the most effective manner for you and for your computer;

  • As part of our efforts to keep our site safe and secure.

3.3    Information we receive from other sources. 

We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4. Do we share your Personal Information with any third parties?

Ducommun does not sell your Personal Information to any Third Parties. To provide the services we offer we may share personal information with our affiliates and service providers who perform services on our behalf based on our instructions. You agree that we have the right to share your Personal Information with selected third parties, including:

  • Business partners, distributors, suppliers and sub-contractors for the performance of any contract we enter into with them or you;

  • Analytics and search engine providers that assist us in the improvement and optimization of our site.

We may disclose your personal information to third parties in the following circumstances:

  • You request or authorize it;

  • The information is provided to help complete a transaction for you;

  • The information is provided to comply with the law, applicable regulations, court orders or subpoenas, to enforce our Terms of Use or other agreements, or to protect our rights, property, or safety or the rights, property, or safety of you or others;

  • The disclosure is done as part of a purchase, transfer or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, personal information relating to customers, suppliers, and vendors may be one of the transferred assets);

  • The information is provided to our agents, outside vendors, or service providers to perform functions on our behalf (e.g. analyzing data, providing marketing assistance, providing customer service, processing orders, etc.);

  • We believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual espionage, cybersecurity events, or other fraudulent or illegal activity.

In such circumstances, only Ducommun, and its authorized affiliates, contractors, suppliers, or service providers will have access to your Personal Information. These third parties are required to act in accordance with the instructions we give them and they must meet the requirements of the law. We ensure that they agree to put in place adequate measures to safeguard your Personal Information, and they will be required to use any Personal Information for only the intended purpose for which it was shared.

We may share your Personal Information with other companies so that they can contact you with details of other products or services you may be interested in. We will only do this if you have agreed to this and where such companies agree to use your personal information for that purpose only. You can ask us not to continue to provide your personal information to any third parties in future by contacting us at the address below.

5. Where we store your Personal Information

We may transfer the personal information about you to recipients in countries other than the country in which the information was originally collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries, we will protect that information as described in this Privacy Policy.

6. How we protect your Personal Information

Ducommun uses reasonable and appropriate measures to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing undertaken and the nature of the Personal Information we collect. We maintain physical, administrative and technological safeguards to protect your Personal Information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Site via the Internet. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

7. How long we store your Personal Information

We will keep your Personal Information for as long as we need it, or as otherwise prescribed by law, for the purposes set out above. This period will vary depending on your interactions with us. We may also keep a record of correspondence with you (for example if you have made a complaint about a product or service) for as long as is necessary to protect us from a legal claim. In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Unless this is the case, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.

Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

8. Additional Policies In Compliance with the CCPA

The CCPA affords California consumers the rights with respect to their Personal Information set forth in this section. These rights apply only to California residents, who are not otherwise exempt pursuant to the terms of the CCPA, such as through the Business-to-Business exemption described in section 8.6.

8.1    Right to Know About Personal Information Collected, Used, Disclosed, or Sold

California consumers have the right to request that the Company disclose what personal information it has collected, used, disclosed, and sold over the 12-month period preceding the Company's receipt of such a request. To exercise this right, a California consumer must submit to the Company a verifiable request to know such information. This request can be submitted by following the procedures set forth in Section 8.4 below.

8.2     Right to Request Deletion of Personal Information

California consumers have the right to request the deletion of their personal information collected or maintained by the Company. To exercise this right, a California consumer must submit to the Company a verifiable request to delete such information. This request can be submitted by following the procedures set forth in Section 8.4 below.

8.3     Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

California consumers have the right to not be discriminated against because the consumer exercised any of the consumer's rights under the CCPA. That means that a company may not deny goods or services to the consumer, charge different rates for goods or services, or provide a different level or quality of goods or services if the consumer chooses to exercise their rights under the CCPA (unless the different rate or different level or quality is reasonably related to the value to the business of the consumer's data).

8.4     Submitting a CCPA Data Request

To submit a request to know about the Personal Information we collect about you as described in Section 8.1 or a request for deletion of your Personal Information as described in Section 8.2, please contact CorpComm@ducommun.com

The Company is required to verify the identity of the individual requesting access to a consumer's data or requesting deletion of a consumer's data. To verify your identity, we will rely upon information we have previously collected about you, such as phone calls received from a known phone number or emails received from a known email. We will also rely upon our personal relationship with our customers or vendors to verify the identity of a requester.

If the California consumer submitting a request is not the Company's client, such an individual who requested information through our website or a phone call to our "contact us" number, then we will verify identity by confirmation using the information we collected, such as phone number of email address.

8.5     Authorized Agent

California consumers may designate an authorized agent to exercise a CCPA right on the consumer's behalf. If a consumer utilizes an authorized agent to exercise a CCPA right, the following proof that the agent has been authorized to act on the consumer's behalf will need to be provided:

  • Proof of written permission by the consumer for the authorized agent to act on his or her behalf and separate verification of the consumer; or

  • Proof that the authorized agent holds a power of attorney to act on the consumer's behalf pursuant to Cal. Probate Code §§ 4000-4465.

8.6     Exclusion for Business to Business Information

The rights set forth in this section do not apply to personal information reflecting a written or verbal communication or a transaction between the Company and the consumer, where the consumer is a natural person who is acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with the Company occur solely within the context of the Company conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit or government agency.

8.7     Exclusion for Financial Sector Data

Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) are not subject to the CCPA. With respect to such information consumers do not have the enumerated rights under the CCPA set forth in this section.

9. Additional Policies In Compliance with the EEA Privacy Laws

In addition to the other policies described in this Privacy Policy, residents of the European Union or the EEA are afforded the following additional rights and protections as required by the General Data Privacy Regulation ("GDPR"). The additional rights and protections set forth in this section of this Policy apply only to residents of the European Union or the EEA.

9.1    GDPR Definitions

The following additional definitions apply to this Section of the Privacy Policy:

"Controller" means the company that is the organization that determines the purposes for which, and the manner in which, any Personal Information is Processed and used in its business.

"Processor" means any Person Processing Personal Information.

"Person" means a natural person, corporation, association, organization, partnership, or other legal entity.

"Processing" is any activity that involves use of the Personal Information. It includes, without limitation, obtaining, recording or holding the Personal Information, or carrying out any operation or set of operations on the Personal Information including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring Personal Information to third parties.

9.2    The legal basis for processing your Personal Information

In order to comply with the GDPR, we are required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for processing your Personal Information will typically be one of the following:

  • Our own legitimate business interests, or the legitimate business interests of our third party partners, promoters, affiliates, distributors, suppliers, vendors, and subcontractors, such as, for example, providing direct marketing to our customers of our products and services that we think would be of interest, permitting prospective employees to search and apply for job opportunities, handling inquiries from our promoters, affiliates, distributors, vendors, and customers, or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest;

  • The performance of a contract that we have in place with you;

  • Your consent where appropriate; or

  • Compliance with our legal obligations, including to meet national security or law enforcement requirements.
9.3    Where we store your Personal Information

If you are located in the EEA, we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to countries outside of the EEA, such as United States. The data that we collect from you is stored on our servers and may be transferred within or outside the European Economic Area ("EEA") to areas where privacy laws may be less strict than in the EEA. By submitting your personal information, you agree to this transfer and processing. We will take all reasonable steps necessary to ensure that your personal information is treated securely in accordance with this Privacy Policy and has the required adequate protection if it is processed or transferred outside the EEA.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

9.4    Addendum to how long we store your Personal Information

In some cases, there is a legal requirement to keep Personal Information for a minimum period of time. Except in those circumstances, we do not keep your Personal Information for any longer than is necessary for the purposes for which the Personal Information was collected or for which it is to be further processed.

9.5    Your rights with respect to your Personal Information

Subject to certain exceptions, you have the following rights with respect to your Personal Information:

  • To receive or access a copy of the Personal Information that we hold about you;

  • To request that any inaccurate or incomplete Personal Information be corrected or supplemented;

  • To have your Personal Information erased, unless we have a legitimate reason to retain the Personal Information (such as if we are required to do so for legal reasons); and

  • To ask us not to process your Personal Information for a particular purpose, including for marketing.
All of these rights are subject to certain conditions and exemptions. For example, the Company will not be obligated to erase your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.

To exercise any of these rights, please submit a written request to us using the contact information set forth below. The Company reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations.

10. Access to your Personal Information

To check that any information you have provided to the Company is accurate and up to date, to inform the Company of any changes, or to learn what information the Company holds about you, please submit a written request to Ducommun's Senior Director, Corporate Compliance at the address provided in the Changes to the Privacy Policy and Contacting Us section of this policy. The Company reserves the right to charge a fee in dealing with such a request as permitted by applicable law and regulations.

You have the right, at any time, to object to the use of your Personal Information for direct marketing purposes and/or the receipt or further receipt of specific or all types of marketing information, or to object to the use of your Personal Information for any processing activity. To do so, you can direct your request by post to the address listed below or by e-mail.

11. Protecting Children's Privacy

Our Site is not designed nor intended to be used by children under the age of 18 ("Minors"). We do not knowingly collect Personal Information from Minors. If you are under the age of 18, please do not submit any information to us.

12. Links to other websites

Our Site may include links to and from other websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites are not covered by this Privacy Policy. We are not responsible for the privacy practices of any third parties or the content of linked sites although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or websites. This Privacy Policy only applies to how Ducommun deals with your Personal Information, and it does not apply to any other company or any other company's websites even if you access them via our Site. Please check these policies before you submit any Personal Information to these websites.

13. Changes to our privacy policy and contacting us

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy and notice.

This Site is owned and operated by Ducommun. If you have any questions or suggestions with respect to this Privacy Policy, please write to us at:

Ducommun Incorporated
200 Sandpoint Avenue, Suite 700
Santa Ana, CA 92707-5759

or you can simply click on Contact Us to send us an email.

 

Effective Date: July 8, 2020

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