Introduction and Scope

This Privacy Notice explains how CentroMotion processes personal data when you interact with us as a customer, supplier, business partner, or website visitor.

“CentroMotion”, “we”, “us”, or “our” refers to the global manufacturing group headquartered in the United States and its subsidiaries, divisions, and brands, including:

In this Notice, “CentroMotion” (“we”, “us”, “our”) refers to CentroMotion and its group companies, subsidiaries, and brands. This includes, but is not limited to:

• Carlisle Brake & Friction
• Elliott Manufacturing
• Gits Manufacturing Co.
• maximatecc
• Power-Packer
• Weasler Engineering

Please see the Schedules to this Privacy Notice for additional privacy information specific to your region, where applicable.

• Schedule 1: EEA & UK
• Schedule 2: California
• Schedule 3: Rest of United States
• Schedule 4: Rest of World

 

Identity of the Controller

For the purposes of data protection laws, the “controller” of your personal data determines how and why it is processed. Depending on your relationship with us, the controller will be:

• For website and marketing data: Our Global Headquarters in the United States is the primary controller for operating our websites, managing global marketing campaigns, and centralizing our Customer Relationship Management (CRM) systems.
• For sales and contracts: The specific CentroMotion subsidiary or local entity that you (or your employer) are doing business with is the controller.

CentroMotion’s Global Headquarters address:

CentroMotion
N19W24200 Riverwood Drive Suite 300
Waukesha, WI 53188
USA

If you are unsure which entity controls your data, or if you have questions about how these entities work together, please contact the Privacy Team on privacy@centromotion.com.

 

Personal Data We Collect

We collect personal data about you to facilitate our business relationship. The types of personal data we collect depends on our relationship with you, and may include:

• Information you provide to us:
  • Business contact details: Name, job title, company name, business email address, business telephone number, location.
  • Consumer contact details: Name, personal email address, shipping address, personal telephone number.
  • Business financial data: Corporate bank account details, VAT/tax ID numbers, billing addresses.
  • Consumer financial data: Payment card information (Processed via secure payment gateways. We do not store full credit card details).
  • Communications: Information provided when you contact customer support, fill out a web form, or sign up to a newsletter.
  • Visitor information: If you visit our physical locations, we may collect your name, company, vehicle license plate, time of arrival and departure, and government issued-ID, where applicable.
• Information we collect automatically:
  • Device and usage data: IP address, browser type, operating system, device type, referring URLs, pages visited.
  • Cookies: Data collected via cookies and similar technologies (see our Cookies Policy for more information).
  • CCTV footage: If you visit our physical locations, your image may be captured by security cameras.
• Information from other sources:
  • Due diligence: We may collect data from credit reference agencies, sanctions lists, or public registers to conduct background checks and credit assessments.
  • Distributors and dealers: We receive end-user contact details from our authorized buyer network to provide warranties and technical support.
  • Marketing partners: We may receive business contact information from lead generation or trade show providers.

 

Purposes of Processing

We process your personal data for a range of purposes related to our legitimate business activities and legal obligations. These purposes may include:

• Order fulfilment and customer service:
  • Processing orders, arranging shipping, and managing returns.
  • Providing technical support, quotes, warranty administration, and responding to inquiries.
• Business administration:
  • Managing our relationship with customers, suppliers, and distributors.
  • Invoicing, accounting, and credit control.
  • Conducting due diligence and sanctions screening.
• Direct sales:
  • Processing consumer purchases, verifying payments, fraud prevention, and delivering products.
• Marketing and events:
  • Sending newsletters, product updates, and event invitations.
  • Managing your marketing preferences.
• Website security and improvement:
  • Monitoring website traffic, load balancing, preventing cyberattacks.
  • Analyzing user behavior to improve our digital services.
• Physical security:
  • Ensuring the safety of our premises and staff via CCTV surveillance and visitor logs.
• Legal compliance:
  • Complying with tax reporting, export controls, health and safety regulations, and cooperating with law enforcement and regulators.

 

Data Sharing and Disclosures

We may share your personal data with third parties and service providers, including:

• Other members of the CentroMotion group, including our US headquarters and other group companies.
• Service providers, including:
  • Logistics and freight: Shipping companies who help deliver our products.
  • Payment processors: Secure payment gateways to process credit card transactions.
  • Marketing platforms: Software to help manage newsletters and email campaigns.
  • IT and security: Cloud storage providers, website hosting services, and security monitoring providers.
  • Analytics providers to help us understand how people use our websites.
• Distributors and dealers: If you request a quote or product support, we may pass your contact details to an authorized distributor or dealer in your region to fulfill your request.
• Regulators including tax authorities, customs officials, or law enforcement agencies.

If CentroMotion is involved in a merger, acquisition, or asset sale, your personal data may be transferred to another party as part of this process.

 

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

• Customer and supplier data: We retain business contact details and transaction history for the duration of our relationship plus the statutory limitation period to resolve any legal disputes and auditing obligations.
• Marketing data: We retain your marketing contact details until you unsubscribe or ask us to delete them. If you opt out, we may keep a limited record of your email address to ensure we do not contact you again.
• CCTV footage: Where we operate video surveillance at our physical locations, footage is automatically overwritten after a short period unless an incident is recorded that requires further investigation.
• Cookies data: See our Cookies Policy for more information.

Your Rights (General)

Under data protection laws, you have specific rights regarding your personal information. While these rights vary depending on the country where you work, generally you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Ask us to correct inaccurate, incomplete, or out-of-date personal data.
• Deletion: Request that we erase your personal data.

Note that these rights are not absolute, and we may be required to withhold or retain certain personal data for legitimate purposes.

For more information about the data protection rights available in your specific region, see the relevant Schedule to this Privacy Notice, below.

To exercise your rights, please contact privacy@centromotion.com.

Updates to this Notice

We may update this Notice from time to time to reflect changes in our technology, legal obligations, or business operations.

We will notify you of any significant changes through our internal communication channels (e.g., email or the company intranet).

Effective date: This Notice was last updated on May 1, 2026

Contact Us

If you have any questions about this Notice or how we handle your personal data, please contact the Privacy Team: privacy@centromotion.com

 

Schedule 1: EEA & UK

This Schedule 1 applies to you if you are located in the United Kingdom (UK) or the European Economic Area (EEA).

Lawful Bases for Processing

Under the GDPR and UK GDPR, we must have a valid legal reason (“lawful basis”) for processing your personal data. We rely on the following lawful bases:

Processing purpose	Lawful basis
Order fulfilment and customer service: Processing orders, arranging shipping, and managing returns; providing technical support, quotes, warranty administration, and responding to inquiries.	Performance of a contract: We need to process this personal data to deliver products, manage warranties, and provide support as agreed in our contract with you or your company.
Business administration: Managing our relationship with customers, suppliers, and distributors; invoicing, accounting, and credit control; conducting due diligence and sanctions screening.	Legitimate interests: To manage our relationship with our customers, maintain our CRM database, and ensure efficient business operations. Legal obligation: To comply with tax, accounting, and anti-money laundering laws.
Direct sales: Processing consumer purchases, verifying payments, fraud prevention, and delivering products.	Performance of a contract: To process your payment and deliver your order. Legitimate interests: To prevent fraud.
Marketing and events: Sending newsletters, product updates, and event invitations; managing your marketing preferences.	Consent: In some circumstances, we will send marketing with your permission. Legitimate interests: We may send relevant product updates and newsletters to promote and grow our business.
Website security and improvement: Monitoring website traffic, load balancing, preventing cyberattacks; analyzing user behavior to improve our digital services.	Legitimate interests: To keep our website secure, prevent cyberattacks, and ensure the site functions correctly.
Physical security: Ensuring the safety of our premises and staff via CCTV surveillance and visitor logs.	Legitimate interests: To protect our premises, assets, and staff.
Legal compliance: Complying with tax reporting, export controls, health and safety regulations, and cooperating with law enforcement and regulators.	Legal obligation: To meet our legal obligations in these areas.

 

International Data Transfers

Where your personal data is transferred to jurisdictions outside the UK or EEA, we rely on Standard Contractual Clauses (SCCs) adopted by the European Commission and implemented into the UK International Data Transfer Addendum where applicable. You have the right to request a copy of these safeguard mechanisms by contacting the Privacy Team.

UK and EEA Rights

In addition to the rights listed in the main Privacy Notice, you have the following rights under the GDPR or UK GDPR:

• Objection: You can object to our processing of your personal data where we rely on “legitimate interests” if you feel it impacts your fundamental rights.
• Restriction: You can ask us to suspend the processing of your personal data, including if you have asked us to verify its accuracy.
• Portability: You can ask that we transfer your data to you or another organization in a structured, electronic format under certain conditions.
• Withdraw consent: If we have asked for your specific consent to process your personal data, you can withdraw this consent at any time.

 

Right to Lodge a Complaint

If you have any complaints about how we process your personal data, we encourage you to resolve this with us in the first instance. You can contact the privacy team on privacy@centromotion.com.

You also may complain to your local data protection authority:

• UK: Information Commissioner’s Office (ICO): ico.org.uk
• EEA: A full list of data protection authorities is available on the website of the European Data Protection Board (EDPB): https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

 

Schedule 2: California

This Schedule 2 applies to customers, business partners, and website visitors who are California residents. It specifically addresses the requirements of the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

For residents of California, this Schedule 2 serves as your “Notice at Collection” under the CCPA.

Categories of Personal Information Collected and Purposes of Collection

The table below explains how we have collected, disclosed, and sold personal information over the past 12 months.

Category of personal information	Examples	Purposes	Disclosed for a business purpose to a service provider	Sold or shared with a third party
Identifiers	Name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name.	Order fulfilment Business administration Sales Marketing and events Website security	Yes	Yes (for cross-contextual behavioral advertising)
Commercial information	Records of products or services purchased, obtained, or considered (e.g., quote history), and purchasing histories or tendencies.	Order fulfilment Business administration Sales Marketing and events	Yes	No
Internet or network activity	Browsing history, search history, and information regarding your interaction with our websites, applications, or advertisements.	Website security and improvement Marketing and events	Yes	No
Geolocation data	Approximate geolocation data derived from your IP address.	Website security and improvement Marketing and events	Yes	No
Professional or employment-related information	Job title, company name, department, and business contact details.	Business administration Marketing and events Order fulfilment	Yes	No
Sensitive personal information	Financial account: Bank account number, credit card number, or debit card number.	Order fulfilment and customer service Sales	Yes	No
Inferences	Profiles reflecting your preferences, characteristics, and behavior (derived from analytics and purchase history).	Marketing and events Website security and improvement	Yes	Yes (for cross-contextual behavioral advertising)

 

Do Not Sell or Share My Personal Information

We may “share” your personal information (online identifiers, inferences) with advertisers for the purposes of cross-context behavioral advertising.

To opt out of the sale or sharing of your personal information, please use the link provided in the cookie banner.

 

Personal Information of Children Under 16

We do not knowingly collect, sell, or share the personal information of consumers under the age of 16. If we become aware that we have collected data from a child under the age of 16, we will delete it immediately.

Your Rights Under the CCPA

California residents have the following rights under the CCPA:

• The right to know about the personal information we collect about you and how it is used and shared.
• The right to delete personal information collected from you (with exceptions).
• The right to opt-out of the sale or sharing of your personal information (where applicable).
• The right to correct inaccurate personal information we hold about you.
• The right to limit the use and disclosure of sensitive personal information we hold about you (where applicable).
• The right to non-discrimination for exercising your CCPA rights.

To exercise your rights, please email privacy@centromotion.com.

We may need to verify your identity before fulfilling your request.

 

Schedule 3: Rest of United States

This Schedule applies to residents of US states (other than California) that have enacted comprehensive consumer privacy laws. This includes, but is not limited to, residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with similar laws coming into effect.

 

Your Privacy Rights

In addition to the rights set out in the Main Notice, residents of certain US states may have additional rights under comprehensive privacy laws:

• The right to obtain a list of third parties with whom we share your personal data.
• The right to obtain a copy of your personal data in a portable and readily useable format.
• The right to opt out of targeted advertising, the sale of your personal data, and profiling in furtherance of legal and similarly significant effects.

We may use your personal data in a way that constitutes a “sale” or “targeted advertising” under certain state laws.

To exercise your right to opt out, or any of the other rights available to consumers in your state, please email privacy@centromotion.com. We may require additional information to verify your identity.

 

Right to Appeal

If you are unsatisfied with how we have handled your privacy request, you may have the right to appeal.

You may appeal the decision via email: privacy@centromotion.com. In certain states, you may also have the right to appeal to your Attorney General.

 

Schedule 4: Rest of World

This Schedule applies to you if you are located in one of the countries set out below. It supplements the main Privacy Notice with information required under the data protection laws of those countries. Where there is any conflict between this Schedule and the main Notice, this Schedule prevails for residents of the relevant country.

 

Argentina

We process your personal data in accordance with the Personal Data Protection Act (Law No. 25.326). We rely on your consent, the performance of a contract, or our legitimate interests, as applicable (see the main Notice).

You have the right to access your personal data free of charge at intervals of not less than six months, and to request the rectification, updating, or deletion of personal data that is inaccurate or processed in breach of the law.

Where we transfer your personal data outside Argentina to countries that do not provide an adequate level of protection, we put in place contractual safeguards permitted under Argentine law.

You may lodge a complaint with the Agency for Access to Public Information (Agencia de Acceso a la Información Pública).

 

Australia

We handle your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

You may request access to, and correction of, the personal information we hold about you.

We may disclose your personal information to overseas recipients, including other members of the CentroMotion group and our service providers, which may be located in the United States and other countries.

If you have a complaint about how we have handled your personal information, please contact privacy@centromotion.com in the first instance. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC).

 

Brazil

We process your personal data in accordance with the General Data Protection Law (Lei Geral de Proteção de Dados, Law No. 13.709/2018).

We process personal data according to the legal bases set out in the law, including your consent, the performance of a contract, compliance with a legal obligation, or our legitimate interests (see the main Notice).

You have the right to confirm the existence of processing; to access your data; to correct incomplete, inaccurate, or out-of-date data; to request anonymization, blocking, or deletion of unnecessary or excessive data; to data portability; to information about the entities with whom we have shared your data; and to withdraw consent.

Where we transfer your personal data outside Brazil, we rely on a transfer mechanism permitted under the law, such as standard contractual clauses or your specific consent.

You may exercise your rights, or lodge a complaint, by contacting privacy@centromotion.com. You may also lodge a complaint with the National Data Protection Authority (Autoridade Nacional de Proteção de Dados, ANPD).

 

China

We process your personal information in accordance with the Personal Information Protection Law (PIPL).

Where we rely on your consent, you may withdraw it at any time, and we will obtain your separate consent where the law requires it, including for the processing of sensitive personal information and for transfers of your personal information outside China.

You have the right to access, copy, correct, and delete your personal information, to request an explanation of our processing rules, and to restrict or object to processing in certain circumstances.

Where we transfer your personal information outside China, including to other members of the CentroMotion group and our service providers in the United States and other countries, we put in place a transfer mechanism permitted under the law and, where required, carry out a personal information protection impact assessment. To exercise your rights, please contact privacy@centromotion.com.

 

India

We process your personal data in accordance with applicable Indian data protection law, including the Digital Personal Data Protection Act 2023 as it comes into force.

Where we rely on your consent, we will ask for it for a specified purpose, and you may withdraw it at any time. You have the right to access a summary of the personal data we process and the processing activities undertaken, to request correction, completion, updating, and erasure of your personal data, and to nominate another individual to exercise your rights in the event of your death or incapacity.

We provide a means for you to make a grievance regarding our processing. If your grievance is not resolved, you may lodge a complaint with the Data Protection Board of India. To exercise your rights or raise a grievance, please contact privacy@centromotion.com.

 

Japan

We handle your personal information in accordance with the Act on the Protection of Personal Information (APPI). We use your personal information within the scope of the purposes of use notified or published by us, and we will obtain your consent where the law requires it. You may request disclosure, correction, addition, deletion, or the cessation of use or provision of your retained personal data.

Where we provide your personal information to third parties outside Japan, including other members of the CentroMotion group and our service providers, we do so in accordance with the requirements of the APPI, including by obtaining your consent or putting in place appropriate measures where required.

To exercise your rights, please contact privacy@centromotion.com.

 

Mexico

We process your personal data in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares).

You have the right to access, rectify, cancel, or object to the processing of your personal data (the “ARCO” rights), to withdraw consent where you have given it, and to limit the use or disclosure of your personal data.

Where we transfer your personal data to third parties, including outside Mexico, we do so as permitted under the law. To exercise your ARCO rights or to limit the use or disclosure of your data, please contact privacy@centromotion.com. You may also seek the protection of the competent supervisory authority.

 

Turkey

We process your personal data in accordance with the Law on the Protection of Personal Data (Law No. 6698, “KVKK”).

We process personal data on one of the legal grounds set out in the law, including your explicit consent where no other ground applies. You have the right to learn whether your personal data is processed, to request information about the processing, to learn its purpose and whether it is used accordingly, to know the third parties to whom it is transferred, to request correction, deletion, or destruction, and to object to any result arising from the analysis of your data by automated means.

Where we transfer your personal data abroad, including to other members of the CentroMotion group and our service providers, we do so on a basis permitted under the law. To exercise your rights, please contact privacy@centromotion.com. You may also lodge a complaint with the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu, KVKK).