Privacy & Cookies Statement

Effective Date: 01/13/2026

This Privacy & Cookies Statement describes how sarclad ("Company", “we”, “us”, or “our”) collects, uses, shares, and otherwise processes Personal Data (as defined below) about individuals when they visit, use, or interact with our website sarclad.com and any other site or other digital property that links to this Privacy & Cookies Statement, or our emails (our “Sites”); purchase our products; apply for a job with our company; or otherwise interact with us online and offline (altogether referred to as our “Services”). For purposes of this Privacy & Cookies Statement, “Personal Data” means any information that is related to or is reasonably capable of being associated with an individual (“you”).

If you are a resident of the European Economic Area ("EEA”), Switzerland, or the United Kingdom ("UK”), please see section 8 below for more information on how we process Personal Data and your privacy rights.

1. Collection of Personal Data

We collect Personal Data about employees and other representatives of our business customers, consumers, individuals who visit our Sites, individuals who use our Services, and other individuals who interact with us. We may collect this data directly from the individual, but also from automated technologies (such as cookies and other tracking technologies) and, when authorized by applicable laws, from other legal entities, such as our customers, third-party partners, advertising networks, social media platforms, and other companies and organizations. We may combine Personal Data that we receive from various sources for the below purposes. The categories of Personal Data that we may collect include:

• Identifiers and contact information, such as your name, account identifiers, email address, IP address, postal address, phone number, or other similar information.
• Demographic information/protected classifications, such as age and gender.
• Commercial and transactional information, such as payment card/payment details or other financial information to provide and/or finance the Services and products you have purchased, obtained, or considered purchasing with us; transaction history; and subscription information.
• Professional or employment-related information, such as your company name and job responsibilities.
• Visual and other sensory information, such as photographs or video of you if, for example, you visit our facilities.
• Education information, such as educational institutions attended.
• Geolocation information, such as the location of a device derived from its IP address.
• Internet and other electronic network activity information, such as your unique device identifiers, data about usage of and interaction with our Sites, our products and Services or advertisements, your account and marketing preferences, and information collected from cookies and other data tracking technologies.
• Records about you, such as your signatures, communications with us, and feedback/rating you have given to us.

If you are applying to a job at our Company (an “Applicant”), we may collect the following categories of Personal Data directly from you, from references you provide, or from third-party partners we engage for recruiting purposes:

• Identifiers and contact information, such as your name, postal address, email address, IP address, or other similar identifiers and contact information.
• Demographic information/protected classifications, such as your age, gender, and, in some countries, veteran status.
• Professional or employment-related information, such as your work history, professional experience, references, and work-permit status (if required).
• Visual and other sensory information, such as photographs or video taken by cameras within our facilities or during our online interviews.
• We may draw inferences about applicants’ characteristics, abilities, and aptitudes from Personal Data provided to us in connection with an application.
• Sensitive Personal Data, such as your ethnic or racial background, health information, your disability status, and sexual orientation information and information about criminal convictions and offences only to the extent we are able to collect such information under applicable laws.
• Any other Personal Data you choose to provide to us in connection with your application.

The provision of certain types of Applicant Personal Data may be mandatory or optional. Mandatory data will be marked as such at the point of collection. If you refuse to provide mandatory data, the Company may not be able to process your request.

2. Use of Personal Data

The purposes for which we use Personal Data are as follows:

3. Disclosure of Personal Data

We may disclose Personal Data that we collect with the following categories of recipients:

• Within the affiliated group: We disclose Personal Data with our ultimate parent company, Heico Holding, Inc., in the United States and its subsidiaries (collectively, "HEICO") as necessary for the purposes identified above.
• Vendors and agents working on our behalf: We disclose Personal Data to third parties to perform functions on our behalf for the purposes identified above, such as IT services, web hosting and marketing, data storage, shipping and logistics, and business support.
• Distributors and sales representatives: We disclose Personal Data to our distributors and sales representatives to complete transactions, respond to inquiries, manage accounts, and otherwise manage our relationships with our customers and their representatives.
• Business partners: We disclose Personal Data to our business partners for our and their own purposes, such as companies that operate cookies and other tracking technologies. We are not responsible for the privacy policies or practices of these companies when they use Personal Data for their own purposes. We encourage you to familiarize yourself with their privacy policies to understand how they process Personal Data.
• Auditors, advisors, and financial institutions: We disclose Personal Data with auditors for the performance of audit functions, with advisors to receive legal and other advice, and with financial institutions concerning payment and other transactions and services.
• Corporate purchasers: We may disclose Personal Data with any corporate purchaser or prospect to the extent permitted by applicable laws as part of any merger, acquisition, sale of Company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of Company.
• Mandatory disclosures and legal rights: We disclose Personal Data to comply with any subpoena, court order or other legal process, or other governmental or regulatory request to share Personal Data, to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

We may disclose each of the categories of Applicant Personal Data that we collect with the following categories of recipients:

• Within the affiliated group: We disclose Personal Data with our ultimate parent company, Heico Holding, Inc., in the United States and its subsidiaries (collectively, "HEICO") as necessary for the purposes identified above.
• Vendors and agents working on our behalf: We disclose Personal Data to third parties to consider individuals for employment and contractor opportunities and manage onboarding procedures.
• Corporate purchasers: We may disclose Personal Data with any corporate purchaser or prospect to the extent permitted by law as part of any merger, acquisition, sale of Company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Data would be transferred as an asset of Company.
• Mandatory disclosures and legal rights: We disclose Personal Data to comply with any subpoena, court order or other legal process, or other governmental request to share Personal Data, to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.

We may share your Personal Data with other entities, with your consent if required by applicable laws. If you have questions about the parties with which we disclose Personal Data, please contact us as specified below.

4. Marketing Communications Choices

You have control regarding our use of Personal Data for marketing communications. If you no longer wish to receive our marketing emails, you may choose not to receive such communications at any time. Please follow the unsubscribe link in the relevant communication or contact us as detailed below.

5. Cookies

We use and allow certain trusted partners to use cookies, web beacons, and similar tracking technologies (collectively, "cookies") on our Sites.

What are cookies?

Cookies are technologies that collect, store, or retrieve information when visiting online services. Cookies are widely used by websites, mobile applications, software or emails. Our Sites may use cookies to collect information. This information might be about you, your preferences or your device and is used to make the site work as you expect it to and for other purposes described below. The information can give you a more personalized web experience. Some cookies are deleted once you close your browser, while others are retained even after you close your browser so that you can be recognized when you return to a website.

How do we use cookies?

We use cookies to provide the Sites, products, and Services, gather information about your usage patterns when you navigate these Sites to enhance your personalized experience, and understand usage patterns to improve our Sites, products, and Services. We also allow certain trusted partners to place cookies on our Sites to collect information about your online activities on our Sites over time and across different websites you visit. This information is used to provide advertising tailored to your interests on websites you visit, also known as interest-based advertising, and to analyze the effectiveness of such advertising. In this context, the Company acts as a joint data controller for the collection and transmission of data to the third-party but only to the extent that it is technically necessary. Beyond the collection and technical transmission, the Company does not have any control over how data collected through third-party cookies is processed.

Cookies on our Sites are generally divided into the following categories:

• Essential Cookies: These are required to operate our Sites. They include, for example, cookies that enable you to log into secure areas.
• Analytical/Performance Cookies: These allow us to recognize and count the number of users of our Sites and understand how such users navigate through our Sites. This helps improve how our Sites work, for example, by ensuring that users can find what they are looking for.
• Functionality Cookies: These improve the functional performance of our Sites and make them easier for you to use. For example, these cookies are used to remember your language preferences.
• Advertising Cookies These record your visit to our Sites, the pages you have visited, and the links you have followed to recognize you as a previous visitor and to track your activity on the Sites and other websites you visit. See below for further details on third-party targeting cookies.

What are your options if you do not want cookies on your computer?

You can manage your cookie preferences on our Sites using the banner located at the bottom of each Site. Follow the instructions in the banner to exercise your choice.

You can review your Internet browser settings, typically under "Help" or "Internet Options," to exercise your choices for certain cookies. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important functions or features of these Sites, and you may be required to re-enter your login details.

We may use Google Analytics to better understand how our Sites are used and to improve them. To learn more about how Google Analytics , please visit https://policies.google.com/technologies/cookies.

Given the divergent practices of organizations that offer browsers and the lack of a standard in the marketplace, we do not respond to do-not-track signals at this time.

6. Notice to Residents in California

This section applies only to residents of California. It supplements the remainder of this Privacy & Cookie Statement.

Regarding “Sharing” and “Selling” Personal Data for Targeted Advertising. We may share your Personal Data with third parties to perform advertising activities relating to marketing, analytics, or service performance measurements. This type of processing may also constitute a “sale” of Personal Data or “sharing” of Personal Data for targeted advertising under applicable data protection law. We may sell or share the following categories of Personal Data to business partners for such purposes: identifiers and contact information, demographic information/protected classifications; commercial and transactional information, and internet and other electronic network activity information.

We do not sell your Personal Data to third parties in exchange for money, nor do we knowingly sell or share the Personal Data of children under 16 years old.

Sensitive Personal Data. We use and disclose your Sensitive Personal Data only to: (i) perform services or provide goods reasonably expected by an average person; (ii) detect security incidents; (iii) resist malicious, deceptive, fraudulent or illegal actions: (iv) ensure the physical safety of persons; (v) for short-term, transient use, including non-personalized advertising; (vi) perform internal business services; (vii) verify, maintain, or improve the quality of our products and services; and (viii) for purposes that do not infer characteristics about you.

7. Your Privacy Rights.

Depending on where you live and our relationship with you, you may have the following rights concerning your Personal Data, subject to certain exceptions:

• The right to know what Personal Data we have collected about you, including the categories of Personal Data, the categories of sources from which the Personal Data is collected, the business or commercial purpose for collecting, “selling,” or “sharing” Personal Data, the categories of third parties to whom we disclose Personal Data, and the specific pieces of Personal Data we have collected.
• The right to rectify or correct inaccuracies regarding your Personal Data;
• The right to restrict processing. You may request that we restrict the processing of your Personal Data in certain cases.
• The right to request the deletion of your Personal Data.
• The right to object. You may have the right to object to the processing of your Personal Data in certain cases, including regarding direct marketing.
• The right to data portability;
• The right to withdraw your consent
• The right to opt-out of processing for the purposes of targeted advertising: You may have the right to opt-out of the sale of your Personal Data and sharing of your Personal Data for targeted advertising. To opt-out, navigate to the banner located at the bottom of the Site and follow the instructions to exercise your choice. Alternatively, you can contact us at +1 888-388-0730 or privacy@heicocompanies.com.

Depending on where you live, you may have the right to appeal any denials of your request to exercise your rights. If we deny your request and you would like to submit an appeal, please contact +1 888-388-0730 or privacy@heicocompanies.com. Further, you may have the right to lodge a complaint with the European relevant data protection supervisory authority. Where applicable, you can find contact information for your data protection supervisory authority on the European Data Protection Board’s website, https://edpb.europa.eu/about-edpb/about-edpb/members_en, or through other publicly available sources.

Exercising your Privacy Rights. If you wish to request the exercise of your privacy rights, we will not discriminate or retaliate against you by offering you different pricing or services, or by providing you with a different level or quality of services, based solely upon this request. Please contact us at +1 888-388-0730 or privacy@heicocompanies.com if you would like to exercise such rights. You may be able to designate an authorized agent to exercise your rights on your behalf. Your authorized agent should contact us at +1 888-388-0730 or privacy@heicocompanies.com to exercise rights on your behalf. We may take steps to verify your or your authorized agent’s identity when we process the request. To verify your identity when you make a verifiable request, we may need additional information from you, such as your name, email address, and employer. If an authorized agent submits your request, we may require the agent to provide signed permission to act on your behalf, or require you to verify your identity with us or confirm that you provided the agent permission to submit the request your request is verifiable.

8. Additional Notice for European Economic Area, Switzerland and the United Kingdom

This section applies only to Personal Data that is subject to EEA, UK, or Swiss data protection laws. It supplements the remainder of this Privacy & Cookie Statement.

Data Controller. The Company is the entity responsible for the processing of your Personal Data as the independent controller unless another entity has the primary relationship with you. This other entity may be another entity from our corporate group whose Site you are viewing or using, that provides services to you, that markets or provides promotional materials to you, or the primary group entity in the region where you interact with us.

In some cases, more than one Company group entity may make decisions on how your Personal Data is processed, such as when two Company group entities co-sign a contract with you or multiple Company group entities organize an event. In these situations, all such entities are jointly responsible for the lawfulness of the specific processing activities as joint controllers

You can view the locations of companies within our corporate group here or contact us as specified below.

Legal Bases for Processing. We process the Personal Data for the purposes identified in section 2 based on the following legal bases:

International Transfers of Personal Data. Due to the global nature of our operations, some of the recipients we share your Personal Data with may be located in countries outside the EEA, Switzerland, or the UK that do not provide an adequate level of data protection as defined by data protection laws in the EEA, Switzerland, and the UK. Certain third countries, such as Canada and the Republic of Korea, have been officially recognized by the European Commission, Switzerland, and the UK Secretary of State as providing an adequate level of protection. Transfers within our corporate group or to third parties located in third countries that have not received such recognition take place using an appropriate data transfer mechanism in accordance with applicable laws, such as the EU Standard Contractual Clauses (“SCCs”)/UK SCCs Addendum or International Data Transfer Agreement, Swiss Standard Contractual Clauses, Binding Corporate Rules, approved Codes of Conduct and Certifications, on the basis of permissible statutory derogations, such as consent, or any other valid data transfer mechanism issued by the EEA, Swiss, or UK authorities.

Please contact us as specified below if you would like to receive further information about how we transfer your Personal Data or, where available, a copy of the relevant applicable data transfer mechanism.

9. Access to this Privacy & Cookies Statement in Alternative Formats.

Individuals who need assistance accessing this Privacy & Cookies Statement in an alternative format can do so by contacting us at +1 888-388-0730 or emailing privacy@heicocompanies.com.

10. How long do we retain Personal Data?

As a general rule, your Personal Data will only be retained for the period necessary for the accomplishment of the purposes for which said Personal Data was collected, or as necessary to fulfill legal or statutory obligations. In determining when your Personal Information is retained or disposed, we may consider the nature and sensitivity of your Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and applicable legal requirements. Upon request, we will securely delete such data in accordance with applicable laws.

Unless otherwise provided by the applicable laws, your Personal Data will be kept until the end of our relationship with you or your deletion request. For Personal Data collected in the context of the recruitment process, we retain it during the application period and, subject to applicable law, for a limited period after you have applied for a job for which you were not selected to allow you to more easily reapply or to approach you for different positions.

11. What about Personal Data relating to minors?

Our Services are not intended for minors under the age of 16. As such, we do not target our products and Services or knowingly collect Personal Data from children under the age of 16 without appropriate consent as required under applicable law. If we learn that we have processed Personal Data received from an individual under the age of 16 without appropriate consent, we will take reasonable measures to delete the information as soon as possible and not use such Personal Data for any purpose, except where necessary to protect the safety of the minor or others as required or permitted by law. If you believe a minor under the age of 16 has provided us with Personal Data, please contact us at the contact information below.

12. How will we handle any changes to this Privacy & Cookies Statement?

We may update this Privacy & Cookies Statement from time to time as our services and privacy practices change or as required by law. The effective date of our Privacy & Cookies Statement is posted above, and we encourage you to visit our Sites periodically to stay informed about our privacy practices. We will post the updated version of the Privacy & Cookies Statement on our Sites and otherwise inform you or ask for your consent to the changes if legally required. This page reflects the most up-to-date version of our Privacy & Cookies Statement and thus takes precedence over the information provided in any other document.

13. Data Security

We maintain reasonable measures designed to protect Personal Data from loss, misuse, alteration, or unintentional destruction. You also have an essential role in protecting Personal Data. You should not share your username and password and should not reuse passwords. If you have any reason to believe your username or password has been compromised, please contact us.

14. Contact Us

If you have questions or comments regarding this Privacy & Cookies Statement or our privacy practices, please contact us at:

+1 888-388-0730 or privacy@heicocompanies.com