Privacy Shield Policy

LCI Website Privacy Shield Policy

This Privacy Shield Policy (“Policy”) describes how LCI Industries and its wholly-owned United States (“U.S.”) subsidiaries listed in its EU-U.S. and Swiss-U.S. Privacy Shield certifications (collectively, “LCI,” “Company,” “we,” or “us”) collect, use, and disclose certain personally identifiable information received from the European Union, European Economic Area, and Switzerland in the U.S. (“Personal Data”). A full list of our covered entities can be found at https://www.privacyshield.gov/list. This Policy supplements LCI’s Privacy Notice and, unless specifically defined here, the terms in this Policy have the same meaning as in LCI’s Privacy Notice.

LCI complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the U.S., respectively. LCI has certified to the Department of Commerce that it, along with all of the entities listed in its certification, adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy or LCI’s Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. The Federal Trade Commission has jurisdiction over LCI’s compliance with the Privacy Shield.

EU and Swiss Personal Data Collection and Use

LCI’s Privacy Notice describes the categories of Personal Data that we may receive in the U.S. as well as the purposes for which we use that Personal Data. LCI will only process Personal Data in ways that are compatible with the purposes LCI collected it for or subsequently authorized by you. We will provide you with the opportunity to choose (opt out) before we use your Personal Data for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized by you. LCI maintains reasonable procedures to ensure that Personal Data is reliable for its intended use, accurate, complete, and current for as long as LCI retains such information.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. In some cases, we may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in LCI’s Privacy Notice. Where required by the Privacy Shield, we enter into written agreements with third-party agents or service providers limiting their use of the Personal Data to the specified services provided on our behalf, requiring them to provide at least the same level of protection that the Privacy Shield requires, and obligating them to notify us if they make a determination that they can no longer meet their obligation to provide the same level of protection as is required by the Privacy Shield. We take reasonable and appropriate steps to ensure that our third-party agents and service providers process Personal Data transferred in a manner consistent with our Privacy Shield obligations and to stop and remediate unauthorized processing. Under certain circumstances, we may remain liable under the Privacy Shield Principles if our agents process your EU and/or Swiss Personal Data that we transfer to them in a manner inconsistent with the Privacy Shield Principles.

Transfers within a Controlled Group of Entities. If we transfer your EU and/or Swiss Personal Data to one of our LCI-controlled affiliates or subsidiaries, we will ensure the continuity of protection of your Personal Data under the Privacy Shield.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including meeting national security or law enforcement requirements.

Security

LCI maintains reasonable and appropriate security measures in accordance with the Privacy Shield to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. Additional information about our information security efforts can be found in in LCI’s Privacy Notice.

Choices and Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or has been processed in violation of the Privacy Shield, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. We may request specific information from you to confirm your identity and to better understand your request. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request using by using our “Contact Us” information provided below. In some circumstances we may charge a reasonable fee for providing information about your Personal Data. Additional information about your access rights and opt-out rights regarding communications can be found in in LCI's Privacy Notice.

Questions or Complaints

In compliance with the Privacy Shield Principles, LCI commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact us by using our "Contact Us" information provided below.

LCI has further committed to refer unresolved Privacy Shield complaints to the TrustArc Privacy Dispute Resolution service, an alternative dispute resolution provider located in the United States. LCI has designated TrustArc to provide an independent dispute resolution body to address complaints and provide appropriate recourse free of charge to individuals. If you do not receive timely acknowledgment of a complaint submitted to LCI, or if your complaint is not satisfactorily addressed, please contact or visit https://www.trustarc.com/consumer-resources/privacy-shield/ for more information or to file a complaint. The TrustArc Privacy Dispute Resolution services are provided at no cost to you.

Binding Arbitration Under certain conditions, and as a last resort, it may be possible for you to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information, see the U.S. Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please email us at infosec@lci1.com.

Updates/Effective Date

We reserve the right to amend this Policy from time to time. When we do amend this Policy, the revised Policy will be posted here so please visit this web page to view the most current Policy.

Effective Date: April 1, 2018

Last modified: November 20, 2018