Data Protection Policy

Last Updated: January 2026

Introduction

Mark VII Equipment Inc. ("Mark VII or "we" or "our") and our parent company WashTec AG take data protection seriously. This Privacy Policy informs users of the Mark VII Training website how we, as controller within the meaning of the General Data Protection Regulation ("GDPR") and applicable U.S. privacy laws, collect and process personal data in connection with your use of this website and our training services.

We are glad to see that you are interested in our training programs and services. The protection of your personal data is very important to us. Your data are protected in accordance with applicable legal regulations.

Controller and Contact Information

The controller within the meaning of applicable data protection laws is:

Legal Form: Delaware corporation, subsidiary of WashTec AG, ArgonstraŸe 7, 86153 Augsburg, Germany

Categories of Personal Data We Collect

When you use our website, register for training courses, or contact us, we may collect the following categories of personal data:

• Contact Information: Name, email address, phone number, company name, job title, and mailing address
• Account Information: Username, password, and security questions for your user account
• Payment Information: Credit card details, billing address, and transaction history
• Course Enrollment Data: Course selections, enrollment dates, attendance records, and completion certificates
• Technical Data: IP address, browser type and version, operating system, time zone setting, browser plug-in types and versions, and platform
• Usage Data: Information about how you use our website, including pages visited, time spent on pages, and navigation paths
• Communication Data: Your communications with us, including emails, phone calls, and messages through contact forms

How We Collect Your Personal Data

We collect personal data through the following methods:

• Direct Interactions: When you register for courses, create an account, fill out forms, or contact us
• Automated Technologies: As you navigate our website, we automatically collect technical and usage data through cookies and similar technologies
• Third Parties: We may receive personal data about you from analytics providers, payment processors, and other service providers

How We Use Your Personal Data

We process your personal data for the following purposes:

1. Course Registration and Management

• Processing course enrollments and managing your participation
• Providing access to training materials and course content
• Issuing certificates of completion
• Processing payments and managing billing

Legal Basis: Performance of contract (GDPR Art. 6(1)(b))

2. Communication and Customer Service

• Responding to your inquiries and requests
• Providing technical support and customer service
• Sending important updates about your courses or account
• Notifying you of changes to our services or policies

Legal Basis: Performance of contract (GDPR Art. 6(1)(b)) and legitimate interests (GDPR Art. 6(1)(f))

3. Marketing and Promotional Activities

• Sending you information about new courses and training programs
• Providing updates on Mark VII products and services
• Inviting you to special events or webinars

Legal Basis: Your consent (GDPR Art. 6(1)(a)) or legitimate interests (GDPR Art. 6(1)(f))

4. Website Functionality and Security

• Ensuring the technical functionality of our website
• Protecting against fraud and unauthorized access
• Troubleshooting and resolving technical issues
• Analyzing usage patterns to improve our website

Legal Basis: Legitimate interests (GDPR Art. 6(1)(f))

5. Legal Compliance

• Complying with legal obligations and regulations
• Responding to lawful requests from government authorities
• Protecting our legal rights and interests
• Maintaining records for tax and accounting purposes

Legal Basis: Legal obligation (GDPR Art. 6(1)(c)) and legitimate interests (GDPR Art. 6(1)(f))

Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

Within the WashTec Group

We may share your data with WashTec AG and its affiliated companies for business purposes, including providing training services, customer support, and administrative functions.

Service Providers

We work with third-party service providers who process data on our behalf, including:

• Payment processors for handling transactions
• Cloud storage and hosting providers
• Email delivery services
• Analytics and website optimization services
• Customer relationship management (CRM) systems

Legal Requirements

We may disclose your personal data to government authorities, courts, or law enforcement when required by law or to protect our legal rights.

International Data Transfers

As Mark VII is a subsidiary of WashTec AG (based in Germany), your personal data may be transferred to and processed in the European Economic Area. We ensure that appropriate safeguards are in place for such transfers, including:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions for specific countries
• Other legally recognized transfer mechanisms

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

• Course Records: Retained for the duration of your enrollment and for a period after completion as required for certification purposes and legal obligations
• Payment Information: Retained as required by tax and accounting laws (typically 7-10 years)
• Account Information: Retained until you request deletion or your account becomes inactive
• Marketing Communications: Retained until you withdraw consent or opt out

Your Rights

Under applicable data protection laws, you have the following rights:

Right of Access (GDPR Art. 15)

You have the right to obtain confirmation as to whether we process your personal data and to access that data.

Right to Rectification (GDPR Art. 16)

You have the right to have inaccurate personal data corrected and incomplete data completed.

Right to Erasure (GDPR Art. 17)

You have the right to request deletion of your personal data when it is no longer necessary for the purposes for which it was collected.

Right to Restriction of Processing (GDPR Art. 18)

You have the right to request restriction of processing in certain circumstances.

Right to Data Portability (GDPR Art. 20)

You have the right to receive your personal data in a structured, commonly used format and to transmit it to another controller.

Right to Object (GDPR Art. 21)

You have the right to object to processing based on legitimate interests or for direct marketing purposes.

Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority if you believe your data protection rights have been violated.

Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to:

• Remember your preferences and settings
• Analyze how visitors use our website
• Improve website functionality and user experience
• Provide personalized content and advertisements

You can control cookies through your browser settings. However, please note that disabling certain cookies may limit your ability to use some features of our website.

Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or damage. These measures include:

• Encryption of data in transit and at rest (SSL/TLS)
• Regular security assessments and updates
• Access controls and authentication procedures
• Employee training on data protection practices
• Incident response and data breach procedures

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to maintaining industry-standard protections.

Children's Privacy

Our training services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our website and services after changes are posted constitutes your acceptance of the revised policy.

California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

• The right to know what personal information we collect, use, and disclose
• The right to request deletion of your personal information
• The right to opt-out of the sale of personal information (Note: We do not sell personal information)
• The right to non-discrimination for exercising your rights

To exercise these rights, please contact us at legal@washtec.com.

Contact Us

If you have any questions about this Privacy Policy or our data protection practices, please contact us:

For data protection matters relating to our parent company WashTec AG, you may also contact: