Privacy Policy Owen Industries Holdings, LLC

1. INTRODUCTION
Owen Industries Holdings, LLC (“Owen Industries,” “we,” “us,” or “our”) develops and operates mobile and web applications (each, an “App”) for internal business use. This Privacy Policy explains how we collect, use, disclose, and safeguard information in connection with your use of any App published or distributed by Owen Industries, including but not limited to applications available on the Google Play Store, Apple App Store, or distributed through internal enterprise channels.
Each App covered by this policy is an internal business tool made available exclusively to authorized employees and contractors of Owen Industries Holdings, LLC. Our Apps are not intended for use by members of the general public.
By using any Owen Industries App, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue use of the App and contact your IT administrator.

2. INFORMATION WE COLLECT
Depending on the specific App and the features you use, we may collect the following categories of information. Not all categories apply to every App.
a) Authentication Information
Your identity is verified through Microsoft Azure Active Directory (Azure AD). We do not store your password. Authentication tokens are managed by Microsoft’s identity platform and are used solely to authorize your access to Owen Industries systems.
b) Business and Operational Data
Apps may allow you to view, enter, or manage business records relevant to your role. This may include customer accounts, contacts, business records, transaction data, operational information, and related identifiers sourced from Owen Industries’ internal systems.
c) Activity and Workflow Records
Information you enter while using an App, such as work orders, visit logs, sales activities, notes, task completions, or other workflow data relevant to your job function.
d) Device Registration Data
Where push notifications are enabled, an App may register your device with a push notification service. This registration includes a device token assigned by the operating system. No personal device information (such as IMEI, serial number, or hardware identifiers beyond the notification token) is stored beyond what is required for notification delivery.
e) Location Data
With your permission, an App may access your device’s location to support features such as associating work activities with a geographic location. Location data is collected only when the App is in use and only if you have granted location permission through your device’s operating system. You may revoke this permission at any time through your device settings. Location data is used solely for internal business purposes and is not shared with third parties for advertising or profiling.
f) App Usage and Diagnostic Data
Basic technical information such as error logs and diagnostic data may be captured to support troubleshooting and application stability. This data is used solely for operational support and is not used for behavioral profiling or advertising.

3. HOW WE USE YOUR INFORMATION
We use the information collected solely for the following internal business purposes:
• To authenticate and authorize your access to Owen Industries systems
• To enable you to perform job functions supported by the App
• To maintain and synchronize business records with Owen Industries’ internal systems
• To deliver push notifications and alerts relevant to your work
• To support operational workflows and business processes
• To diagnose and resolve technical issues with our applications
We do not use your information for advertising, marketing to third parties, or any purpose unrelated to Owen Industries business operations.

4. INFORMATION SHARING AND DISCLOSURE
We do not sell, rent, or trade personal information. Information may be shared only in the following limited circumstances:
a) Service Providers and Technology Partners
Owen Industries uses a common set of technology infrastructure to operate its applications. Depending on the App, one or more of the following third-party services may be used. Each provider processes data only as necessary to deliver their respective service:
• Microsoft Corporation — Azure Active Directory (authentication and identity management), Azure cloud infrastructure, and Azure Notification Hub (push notification routing). See Microsoft’s Privacy Statement at https://privacy.microsoft.com.
• Google LLC — Firebase Cloud Messaging (push notification delivery to Android devices). See Google’s Privacy Policy at https://policies.google.com/privacy.
• Apple Inc. — Apple Push Notification service (APNs) for push notification delivery to iOS devices. See Apple’s Privacy Policy at https://www.apple.com/legal/privacy.
• SAP SE — Enterprise resource planning system integration (where applicable). Data exchanged with SAP systems is limited to what is necessary for operational integration.
Additional third-party service providers may be used in specific applications. Any such providers will be engaged under appropriate data handling agreements and will process data only as necessary for Owen Industries’ internal business operations.
b) Legal Requirements
We may disclose information if required to do so by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Owen Industries, its employees, or others.
c) Business Transfers
In the event of a merger, acquisition, or sale of assets, information held by Owen Industries may be transferred as part of that transaction. We will provide notice of any such change as required by applicable law.

5. DATA STORAGE AND SECURITY
All business data accessed and stored through Owen Industries Apps is hosted on Owen Industries’ internal servers and Microsoft Azure infrastructure located in the United States. We implement appropriate technical and organizational security measures across all applications, including:
• Encrypted data transmission (TLS/HTTPS) between Apps and our servers
• Azure Active Directory role-based access controls
• Authentication token expiration and secure token storage on device
• Access limited to authenticated and authorized Owen Industries personnel
No method of electronic transmission or storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. DATA RETENTION
Data collected through Owen Industries Apps is retained for as long as it remains relevant to business operations or as required by applicable law. Employee access credentials and device registration tokens are deactivated upon termination of employment or removal of system access by the IT department. Business records and operational data are retained for the duration they serve an active business purpose and are reviewed periodically for continued relevance.
Requests related to the retention or removal of personal information should be directed to the IT department at itdepartment@owenind.com. Access changes and deprovisioning are handled through the standard employee offboarding process.

7. YOUR RIGHTS AND CHOICES
As an Owen Industries employee or authorized user, you may:
• Request access to the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your personal data (subject to legal and operational retention requirements)
• Withdraw consent for push notifications at any time through your device’s notification settings
• Revoke location access at any time through your device’s operating system settings
To exercise any of these rights, please contact itdepartment@owenind.com. We will respond within a reasonable timeframe and in accordance with applicable law.

8. CHILDREN’S PRIVACY
Owen Industries Apps are intended solely for use by adults employed or engaged by Owen Industries Holdings, LLC. We do not knowingly collect personal information from individuals under the age of 13, or under the age of 16 where required by applicable law. If we become aware that a minor has provided personal information through any of our Apps, we will take steps to delete such information promptly.

9. THIRD-PARTY LINKS AND SERVICES
Owen Industries Apps may display references to or integrate with third-party business systems. This Privacy Policy applies only to data handled directly by Apps published by Owen Industries Holdings, LLC. We encourage you to review the privacy practices of any third-party services you interact with.

10. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our applications, practices, technology, or legal requirements. When we make material changes, we will update the “Last Updated” date at the top of this policy. Continued use of any Owen Industries App following an update constitutes your acceptance of the revised policy. The current version will always be available at https://owenmetalsgroup.com/privacy-policy/.

11. CONTACT US
If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact:
Owen Industries Holdings, LLC
Attn: IT Department
501 Avenue H
Carter Lake, IA 51510
United States
Email: itdepartment@owenind.com
Website: https://owenmetalsgroup.com

This privacy policy applies to all mobile and web applications published by Owen Industries Holdings, LLC, including applications distributed through the Google Play Store, Apple App Store, and internal enterprise channels.