EU/Swiss-U.S. Privacy Shield Statement

Effective Date: February 14, 2020

Leggett & Platt, Incorporated, Leggett & Platt Aerospace Middletown, LLC, Precision Hydraulic Cylinders, Inc., Western Pneumatic Tube Company, LLC, Valley Metals, LLC, and L&P Financial Services Co. (collectively, "Leggett") respect your privacy and are committed to safeguarding and protecting your privacy in connection with the collection, use, and retention of personal information transferred from the European Union ("EU"), the European Economic Area ("EEA"), Switzerland and the United Kingdom to the United States (“U.S.”). This EU/Swiss-U.S. Privacy Shield Statement (“Statement”) contains important information regarding Leggett’s privacy practices and the choices it offers individuals with respect to their personal information. If you choose to provide us with personal information, you are telling us that you have read, fully understand, and accept the privacy practices summarized in this Statement and consent to all actions that are consistent with and described in this Statement. We encourage you to read this Statement in its entirety to understand Leggett’s privacy practices before submitting any personal information to Leggett. Leggett is subject to the investigatory and enforcement authority of the Federal Trade Commission ("FTC").

Scope

This Statement applies to our processing of "Personal Information," by which we mean personal information or data that we receive, process or record in the United States from the EU, the EEA, Switzerland and the United Kingdom that identifies, or can be used by us or on our behalf to identify, an individual. This may take the form of contact information, such as your name, home or other physical address, email address, telephone number, fax number, organization name, or job title. Personal Information does not include "Usage Data," which we define as encoded information, aggregate information, anonymized information, or information that is publicly available and not combined with non-public personal information.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

Our normal business operations may require the processing of Personal Information received from the EU, the EEA, Switzerland and the United Kingdom. We participate in the EU-U.S. Privacy Shield Framework and the Swiss-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 EU, the EEA, Switzerland and the United Kingdom to the United States. We have certified to the U.S. Department of Commerce that we adhere to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability (the "Privacy Shield Principles"). If there is a conflict between the privacy practices covered in this Statement and the Privacy Shield Principles with respect to Personal Information received from the EU, the EEA, Switzerland and the United Kingdom, the Privacy Shield Principles shall prevail. To learn more about the Privacy Shield, the Privacy Shield Principles, the requirements for participating companies, such as Leggett, and to view Leggett’s certification, please visit https://www.privacyshield.gov.

Information Collection

Personal Information You Voluntarily Provide. If you voluntarily provide us with Personal Information, we may collect this Personal Information. You may voluntarily provide Personal Information to us in a variety of ways, including by communicating with us orally and via email, subscribing to receive newsletters, registering and attending trade shows, engaging in interactive and community features, requesting event information, participating in surveys and questionnaires, and through other useful content that you have requested. This may take the form of contact information, such as your name, home or other physical address, email address, telephone number, fax number, organization name, and/or job title.

Personal Information We May Automatically Collect. We may use various technologies to collect Personal Information about you when you visit or use our websites ("Sites"), and when we send promotional email communications, including newsletters, to you for which you have registered. These technologies may include:

  • Cookies. Like many websites, our Sites may use "cookies." A cookie is a small information file that some websites transfer to a user’s hard drive. We may use cookies to improve a user’s experience on our Sites, for example, to personalize features of the Sites for you, to analyze the traffic on the Sites, to better understand visitor and customer usage of our Sites, and to maintain and make improvements based on the information we collect. We may also use cookies in promotional email communications we send to you to help us measure the effectiveness of our advertising and how visitors and customers use our Sites, services, and products. The use of cookies has become standard practice for websites and in promotional email communications, but whether you choose to accept or decline these cookies is entirely up to you. If you refuse cookies, you may not be able to use some of the functionality of our Sites or our promotional email communications. Other third parties associated with the Site(s) may also use cookies in connection with the services and websites to which such Site links. We do not control these third-party cookies.

  • Internet Protocol Addresses. Our Sites may use Internet Protocol ("IP") addresses. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, web servers can identify your computer by its IP address. In addition, web servers may be able to identify the type of browser or type of computer you are using, or both. We log IP addresses and related information for the purposes of internal security, trend analysis, and system administration, to assess the traffic on the Sites, and to maintain and make improvements to the Sites. We do not link IP addresses to your Personal Information, but we can and will use IP addresses to identify a user when we believe it is necessary to enforce compliance with this Statement, to protect the Sites, customers, or other visitors, or to comply with applicable laws.

  • Web Beacons. Web beacons are small files that communicate with third parties and are embedded in web pages, ads, or in promotional communications. We may use web beacons to deliver or communicate with cookies, to count users who have visited a web page, to understand usage patterns of our customers and visitors. We also may use web beacons to learn if emails have been opened, acted on, or forwarded. We also may include web beacons in newsletters and other promotional email communications that we send to subscribers in order to count how many newsletters or other promotional communications have been opened or read. You can disable the ability of web beacons to store cookie information by declining cookies. Our web beacons do not collect, gather, monitor, or share any Personal Information about customers or visitors to our Sites. They are merely designed to compile Usage Data, as defined above.

  • Other Technologies. Examples of other technologies we may use to provide better service to you when visiting the Sites include:

    • Web Session Variables. Information that is passed from one web URL to another as you browse.

    • Browser plug-ins/add-ons. Additional web components that may need to be installed to enable certain web features on the Sites. You have the option not to install these components.

Our Sites may contain links to websites operated by others whose privacy practices are different from Leggett’s. This Statement does not apply to any information collected from you through such links or that you may provide on the websites you reach by utilizing those links. Leggett is not responsible for the content or privacy practices of websites linked to the Site(s) or any websites that are not designed and developed by Leggett. You are encouraged to use common sense when using our Sites and review the privacy practices of each website you elect to visit before submitting your Personal Information.

Please be advised that if you disclose Personal Information through discussion forums, message boards, chat rooms, or blogs whose access is provided by Leggett, this information may be collected and used by others. We do not monitor these public spaces and take no responsibility for the security or confidentiality of any information posted thereon.

Information Use

We may use Personal Information to:

  • Operate and better understand usage of the Sites;
  • Deliver services, products, and information to you;
  • Analyze and improve performance of the Sites, our services, products, and information;
  • Learn what new services, products, or information interest you;
  • Tailor our Sites, services, products, and information to meet your needs;
  • Respond to your requests and preferences;
  • Conduct research about your opinion of Leggett, the Sites, and our services, products, and information;
  • Market and advertise our services, products, and information to you and determine the effectiveness of the same;
  • Perform customer service;
  • Enhance internal security and system administration;
  • Report on and analyze industry trends; and
  • Otherwise manage our normal business operations.

While we do not give, sell, rent, or lease any Personal Information collected to third parties, Leggett may disclose information about you to its agents, such as its vendors and service providers, acting on behalf of Leggett under instructions for the limited and specific purpose of assisting Leggett with its normal business operations. In no event will that limited and specific purpose be inconsistent with this Statement. In such cases, we contractually obligate these agents to only use this information in connection with providing services to Leggett.

Sometimes a law, court order, or other judicial or administrative process requires us to provide Personal Information to a government authority or party to a private lawsuit. Upon receipt of a lawful request by public authorities, including to meet national security or law enforcement requirements, we will disclose an individual’s Personal Information. While in all cases Leggett will only provide such information that we in good faith believe is required to comply with the law, order, or other legal process, we may also disclose certain Personal Information if:

  • Leggett is involved in a merger, acquisition, or sale of all or a portion of its assets. You will be notified via email and/or a prominent notice on our Site(s), as applicable, of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information;
  • We are required to bring, or defend against, litigation or any regulatory proceeding between, or relating to, you and us; or
  • We have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other customers, visitors, or users of the Sites, or anyone else who could be harmed by such activities.

Additionally, because Leggett is a global company, we may share your information with other subsidiaries and business units in other parts of the world. These subsidiaries and business units will maintain the privacy of your Personal Information in accordance with this Statement.

Choice

When you provide Personal Information to us, you consent to our using that Personal Information in a manner consistent with this Statement. You have choices about whether we use your Personal Information to communicate with you and, if we do communicate with you, what form that communication takes. We will use your Personal Information as described in the "Information Use" section of this Statement. If you wish for us to stop using your Personal Information for the uses described above, or wish to stop receiving promotional email communications, simply write to us at the address provided below in the Contact Information section, or use the Contact Us form found at https://privacy.leggett.com and provide us with the details of your request. We will respond in a timely manner to your request. You can also stop receiving promotional email messages from us by following the directions provided in the bottom of any such promotional email communication you receive. Further, we will not disclose your Personal Information to any third party for uses other than those described in this Statement without first providing you with notice and a clear choice to "opt-out" of such disclosure.

We do not seek, nor do we knowingly process, so-called "sensitive" Personal Information, unless we have a lawful basis for doing so. This category of Personal Information is more sensitive in nature and relates to, for example, an individual’s race, sexual orientation, criminal allegations or offenses, trade union memberships, their mental or physical health, or their biometric information. We have no intention of processing or disclosing such Personal Information, but if for any reason Leggett needs to disclose "sensitive" Personal Information to any third party, Leggett will only do so pursuant to a lawful basis.

Accountability for Onward Transfer

Prior to making any disclosures to agents – such as vendors and service providers acting on behalf of Leggett under instructions for the limited and specific purpose of assisting Leggett with its normal business operations – we will attempt to ascertain that such agents are providing at least the same level of privacy protection as is required by the Privacy Shield Principles and will take reasonable and appropriate steps to ensure that any third-party agent is processing Personal Information in a manner consistent with our obligations under the EU-U.S. and the Swiss-U.S. Privacy Shield Principles. We will require any third-party agents to notify the organization if that agent determines it is unable to provide the same level of privacy protection as is required by the Privacy Shield Principles. To the extent that we are made aware of the unauthorized processing of your Personal Information, we will take reasonable and appropriate steps to stop and remediate the unauthorized processing. Leggett remains potentially liable under the Privacy Shield Principles if third-party agents that it engages to assist with processing Personal Information on its behalf do so in a manner inconsistent with the Privacy Shield Principles.

Security

We deploy a combination of reasonable and appropriate physical, technical, and administrative safeguards to help protect against the loss, misuse, unauthorized access, disclosure, tampering, alteration, and unauthorized destruction of any Personal Information. We follow generally accepted security standards in our operations to protect the security of your Personal Information, both internally and from outsiders, and to ensure the integrity of the Personal Information we process, taking into account the relative risks involved and the nature of the Personal Information in question. Unfortunately, with any transmission over the Internet, there is always some element of risk involved in submitting Personal Information. If you have any questions about the security of your Personal Information, use the Contact Us form at https://privacy.leggett.com. We will respond in a timely manner to your request.

Integrity, Purpose Limitation, and Access

We will not process Personal Information in a way that is incompatible with the purposes detailed in this Statement. When we receive a specific request from you, we will take all reasonable steps necessary to ensure that your Personal Information is reliable, accurate, complete, current, and relevant to its intended use. We acknowledge EU, EEA Swiss and United Kingdom individuals have the right to access their Personal Information. Upon request, and subject to permissible exceptions, Leggett will grant such individuals access to the Personal Information that it holds about them. In addition, if you believe that the Personal Information you have voluntarily provided to us is, or has become, unreliable, inaccurate, incomplete, untimely, or irrelevant, you may review, revise, correct, or update any of the Personal Information we may have about you, except where the burden or expense of providing access to such review, revision, correction, or update would be disproportionate to the risk to your privacy, where the rights of persons other than you would be violated, where the organization’s confidential commercial information would be compromised, where it would interfere with the execution or enforcement of the law or with a private cause of action, or where it would breach a legal or other professional privilege or obligation. If you have any questions about access to your Personal Information, use the Contact Us form at https://privacy.leggett.com. Once there, you may initiate a request to access, modify, or delete your Personal Information. We will respond in a timely manner to your request.

Retention

We will retain your Personal Information for as long as needed to meet the uses described in the "Information Use" section of this Statement. In addition, even if you opt-out, we may retain your Personal Information for internal use only, where permitted by applicable law.

Handling Process Concerns

For EU, EEA, Swiss and United Kingdom Individuals

In compliance with the EU-U.S. and the Swiss-U.S. Privacy Shield Principles, Leggett commits to resolve complaints about your privacy and our processing of your Personal Information. EU, EEA, Swiss and United Kingdom individuals with inquiries or complaints regarding this Statement should first contact our Privacy and Data Protection Team by visiting us at https://privacy.leggett.com.

Leggett has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, you may visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint free of charge.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Policy Regarding Children

The Sites are not intended for use by children under the age of sixteen (16), and we do not seek, nor do we knowingly process, Personal Information from children under the age of sixteen (16). If you think that we have processed Personal Information from a child under the age of sixteen (16), please contact our Privacy and Data Protection Team immediately by visiting using the Contact Us form at https://privacy.leggett.com. We will respond in a timely manner to your request.

Updates To This Statement

We reserve the right to revise or update our policies and this Statement at any time, consistent with the requirements of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. The "Effective Date" at the top of this Statement reflects the date of the most recent revisions. The most current version of the Statement can be reviewed by clicking on the "Privacy Shield Statement" link located at the bottom of each of our pages associated with the Sites. We encourage you to periodically review this link for the latest information on our privacy practices. Any update to this Statement will become effective when we post the revised Statement on our Sites. Your use of any of our Sites mean that you accept the privacy practices summarized in this Statement and consent to all actions that are consistent with and described in this Statement.

Contact Information

If you have questions about Leggett’s Statement, our privacy practices, or the privacy and security of your Personal Information, please use the Contact Us form at https://privacy.leggett.com. You may also write us at:

L&P Automotive Europe Headquarters GmbH
Attn: Data Protection Officer
Frankenstrasse 150A
90461 Nuremberg
Germany

or

Leggett & Platt, Incorporated
Attn: Associate General Counsel – Privacy & Data Protection
No. 1 Leggett Road
Carthage, Missouri 64836
USA