Disclosures

Last updated: October 1, 2026

Introduction

Fres-co System USA, Inc. (“Fres-co” or “we”) respects your privacy and is committed to protecting your privacy as set forth this Privacy Policy (“Policy”).

This Policy describes the types of information and data we may collect from you or that you may provide when you visit the Fres-co website https://www.fresco.com/ (“Website”), and Fres-co’s practices for collecting, using, maintaining, protecting, and disclosing that information and data.

This Policy applies to information and data we collect:

• On the Website.
• In email, text, and other electronic communication between you and the Website.
• When you interact with Fres-co applications on third-party websites, if those applications include links to this Policy.

This Policy does not apply to information and data collected by:

• Fres-co offline or through any other means, including on any other website operated by Fres-co or any third party (including any Fres-co affiliate); or
• Any third party (including any Fres-co affiliate), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Policy carefully to understand Fres-co’s policies and practices regarding your information and data and how we will treat it. If you do not agree with Fres-co’s policies and practices, your choice is not to use the Website. By using the Website, you agree to this Policy. Where required by applicable law, we will obtain your consent before collecting or using your Personal Information (as defined in this Policy) in ways not described in this Policy. Certain data processing activities may require your affirmative consent, which we will request separately as required. This Policy may change from time to time (See Changes to this Privacy Policy). Your continued use of the Website after we make changes is deemed to be your acceptance of those changes, so please check this Policy periodically for updates.

Information and Data We Collect About You and How We Collect It

We collect several types of information and data from and about users of the Website, including information and data:

• by which you may be personally identified, including your name, title, company name, postal address, email address, telephone number, and fax number; and
• about your internet connection, the equipment you use to access the Website, and your usage details (collectively, “Personal Information”).

We collect this information and data:

• Directly from you when you provide it to Fres-co; and
• Automatically as you navigate through the Website. Information and data collected automatically for security and functionality is not used to identify any specific user or track a specific user’s behavior on the Website, but may include usage details, Internet Protocol (IP) addresses, browser type, and device information and data collected through cookies.

If you are a California resident, the Personal Information described above maps to the following categories under the California Consumer Privacy Act, as amended (“CCPA”): identifiers (such as your name, postal address, email address, telephone number, IP address, and other online identifiers); internet or other electronic network activity information (such as browsing history, search history, and interactions with the Website); geolocation data (general); commercial information (such as information about equipment, products, services, and requests); and professional or employment-related information (such as your title, company name, and job-posting interactions).

If you are a California resident, you may also be entitled to receive a notice at or before the point of collection of your Personal Information. For more information about the categories of Personal Information we collect and the purposes for which they are used, please see the “Information and Data We Collect About You and How We Collect It” and “How We Use Your Information and Data” sections of this Policy.

Information and Data You Provide to Us

The information and data we collect on or through the Website may include:

• Information and data that you provide by filling in forms on the Website. This includes information and data provided when requesting information concerning Fres-co equipment, products or services and when you report a problem with the Website.
• Records and copies of your correspondence (including email addresses), if you contact Fres-co.
• Your search queries on the Website.

If you disclose any Personal Information relating to other persons or entities to Fres-co or to any Fres-co third party service providers in connection with your use of the Website, you represent that you have the authority to do so and to permit Fres-co to use the information and data in accordance with this Policy.

Information and Data We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information and data about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information and data about your computer and Internet connection, including your IP address, operating system, and browser type.

The information and data we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. This helps Fres-co to improve the Website and to deliver a better and more personalized service, including by enabling Fres-co to:

• Estimate the audience size and usage patterns.
• Store information and data about your preferences, allowing Fres-co to customize the Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Website.

The technologies we use for this automatic data collection may include “cookies.” A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. If, however, you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, the system will issue cookies when you direct your browser to the Website. See Fres-co’s Cookies Policy for more information about our use of cookies.

How We Use Your Information and Data

Fres-co does not sell, trade, or rent your Personal Information to others. Nevertheless, our use of certain cookies and similar technologies on the Website may constitute “sharing” of Personal Information for cross-context behavioral advertising purposes as defined under applicable state privacy laws, including the CCPA. You have the right to opt out of this sharing as described in the “Choices about How We Use and Disclose Your Information and Data” and “Your State Privacy Rights” sections, including by using the “Do Not Sell or Share My Personal Information” link available on the Website or contacting us at contact@fresco.com. We may provide aggregated statistical data to reputable third-party vendors, but this data will not include Personal Information. We may, however, use your information and data in one or more of the following ways:

To provide the information, equipment, products or services you requested. This may include sending you electronic newsletters, reminders, confirmation notifications, or enabling you to comment on a webpage. We may also use your information and data for any other purpose expressly disclosed by Fres-co when you provide the information or data.

To communicate with you. We use your information and data to send you customer service, equipment, product or transactional emails. This may include communications regarding the status of a job posting, replies to your email or phone inquiries, emails containing resources you requested, or purchase confirmations. We may also use your information and data to send you samples, materials and additional equipment and product information.

To conduct statistical analysis of the Website. The information and data we collect is used to analyze and ultimately improve the Website to better serve the users of the Website.

To support Fres-co equipment, products and services. We may employ contractors, service providers, and other third parties to support Fres-co’s business, who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.

We engage trusted service providers to maintain the safety, security, and integrity of our Website. These providers process Online Identifiers (such as IP addresses) and Internet Activity Information (such as routing, addressing, and signaling information) strictly for the purpose of detecting malicious traffic, preventing fraud, and ensuring technical functionality. This processing is necessary to protect our users and infrastructure and is not used for cross-context behavioral advertising or building consumer profiles.

To use for other purposes only with your consent. There may be other instances not included here where we may use or collect your information and data. Such instances will only be at your direction or with your consent.

We may also use your information and data to contact you about equipment, products and services that may be of interest to you. If you do not want us to use this information and data in this way, please check “unsubscribe” on any Fres-co mailings or contact us at contact@fresco.com.

Disclosure of Your Information and Data

We may disclose aggregated information and data about users of the Website, and information and data that does not identify any individual, without restriction.

We may disclose Personal Information that we collect or you provide as described in this Policy:

• To Fres-co affiliates.
• To contractors, service providers, and other third parties Fres-co uses to support its business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• To a third party if Fres-co or any Fres-co affiliates are involved in a corporate restructuring.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by Fres-co when you provide the information and data.
• With your consent.

We may also be bound to disclose your Personal Information to authorities and other third parties in circumstances where we believe, in good faith, that doing so is necessary or appropriate to comply with any applicable law, regulation, legal process or governmental request, to detect, prevent or otherwise address fraud, security, or technical issues, or to protect the rights and safety Fres-co and the rights and safety of users of the Website.

Choices about How We Use and Disclose Your Information and Data

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information and data:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly. Cookie detail tables on our Website are dynamically generated by the consent banner framework. Below is the standard structure used by our Cookie Policy:

Your cookie preferences are remembered across sections of the Website and will remain in place until you change your preferences or you clear your cookies and consent again. Please see our Cookies Policy for more information about our use of cookies.

• Promotional Offers from Fres-co. If you do not wish to have your contact information and data used by Fres-co to promote Fres-co’s own or third parties’ equipment, products or services or to opt out of Fres-co’s mailing list, you may do so by sending Fres-co an email stating your request to contact@fresco.com. If we have sent you a promotional email, you may send Fres-co a return email asking to be omitted from future email distributions. This opt out does not apply to information and data provided to Fres-co as a result of a product or equipment purchase, warranty registration, product or equipment service experience, or other transactions.

Accessing and Correcting Your Information and Data

You can update your Personal Information by sending an email to contact@fresco.com to request access to, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change information or data if we believe the change would violate any law or legal requirement or cause the information or data to be incorrect.

Data Security

Fres-co has put in place appropriate organizational, technical and physical safeguards designed to maintain data security and secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We work to protect the security of your information and data notably during transmission using HTTPS to encrypt any data you provide via the Website. Please keep in mind that no manner of data storage or transmission is completely secure and any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. It is also important for you to protect your data, especially to prevent unauthorized access to your password and to your computer. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Data Breach Notification

In the event of a data breach involving your Personal Information, Fres-co will notify you and any applicable regulatory authorities as required by applicable law. Notification may be provided by email, postal mail, or by posting a notice on the Website, depending on the circumstances and as permitted by law.

Data Protection Rights Under General Data Protection Regulation (GDPR)

Fres-co is headquartered in the USA. If you are a resident of the European Union (“EU”), a European Economic Area (“EAA”) member state, or Switzerland, you have certain data protection rights under the GDPR, including:

Where the GDPR applies, Fres-co processes your Personal Information on one or more of the following legal bases, depending on the circumstances: (a) our legitimate interests, including operating, securing, and improving the Website and communicating with you; (b) your consent; (c) performance of a contract with you or taking steps at your request before entering into a contract; and (d) compliance with a legal obligation. Where we rely on consent, you may withdraw it at any time.

• The right to access, update or to delete the information and data we have on you. You have the right to request to access, to update or request deletion of your Personal Information in Fres-co’s possession. If you would like to exercise this right, please contact Fres-co to assist you.
• The right of rectification. If you believe that your Personal Information that we possess is, or has become, incorrect or is incomplete, you have the right request to rectify any of the Personal Information we may have about you.
• The right to object. You have the right to object to Fres-co processing of your Personal Information.
• The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
• The right to data portability. You have the right to be provided with a copy of the information and data Fres-co has on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time, where Fres-co relied on your consent to process your Personal Information, without affecting the lawfulness of Fres-co’s processing based on consent before its withdrawal.

Fres-co may transfer your Personal Information outside the EEA. When required by applicable law, Fres-co uses appropriate safeguards for such transfers, which may include the European Commission’s Standard Contractual Clauses, an adequacy decision such as the EU-U.S. Data Privacy Framework where applicable, or another lawful transfer mechanism.

Please note that we may ask you to verify your identity before responding to any of the above requests and that the above individual rights are not absolute. Fres-co may be entitled to refuse requests where certain exceptions apply. If you have given your consent and you wish to withdraw it, please contact us using the contact details provided at the end of this Policy. Please note that where processing of your Personal Information relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of Fres-co’s equipment, products or services to you, or it may affect the provision of such equipment, products or services.

If you believe that Fres-co has not complied with applicable foreign laws regulating such information and data, you should first contact Fres-co using the contact details provided at the end of this Policy. You also have the right to file a complaint with the appropriate supervisory authority in the EEA about Fres-co’s collection and use of your Personal Information. For more information, please contact your local data protection authority in the EAA. You may also contact Fres-co to be directed to the relevant authorities.

Fres-co does not currently maintain a Data Protection Officer. Our privacy contact can assist with data protection inquiries and GDPR-related requests; please contact us at contact@fresco.com.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your Personal Information, including:

• Access and Data Portability. You may confirm whether we process your Personal Information and access a copy of the Personal Information we process. To the extent feasible and required by state law, depending on your state of residency, data will be provided in a portable format. Depending on your state of residency, you may have the right to receive additional information, which will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your Personal Information that we maintain, taking into account the information’s nature and processing purpose.
• Deletion. You may request that we delete Personal Information about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Sales, Targeted Advertising, and Profiling. You may request that we do not use your Personal Information for sales, targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects. Some states may also grant you the ability to learn more about or challenge those automated decisions.

The exact scope of these rights varies by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, please contact us at contact@fresco.com. We may ask you to verify your identity before responding to a request.

If we deny a request in whole or in part, you may appeal by emailing contact@fresco.com and explaining why you believe the decision should be reconsidered. We will review the appeal and respond within the period required by applicable law. If we deny the appeal, we will explain the reason and provide any further complaint process required by law.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make commercially reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

To opt out of the sharing of your Personal Information for cross-context behavioral advertising, click the “Do Not Sell or Share My Personal Information” link available on the Website or contact us at contact@fresco.com.

Nevada residents may opt out of the sale of certain Personal Information. To submit an opt-out request, please contact us at contact@fresco.com. Please note that we do not currently sell Personal Information as defined under Nevada law (NRS 603A).

Data Privacy Requirements for California Residents

Fres-co is subject to the California Consumer Privacy Act, as amended (“CCPA”), to the extent applicable. This section describes additional privacy disclosures and rights for California residents. The CCPA defines “Personal Information” broadly to include information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For purposes of the CCPA, the categories of Personal Information that Fres-co has collected or may collect include identifiers, internet or other electronic network activity information, geolocation data (general), commercial information, and professional or employment-related information.

We collect and use these categories for the purposes described in the “How We Use Your Information and Data” section, including providing and supporting requested information, equipment, products, and services, communicating with you, analyzing and improving the Website, maintaining safety, security, and integrity, sending marketing and promotional communications where permitted, and complying with legal obligations and enforcing our agreements.

Fres-co does not sell your Personal Information. We note, however, that our use of certain cookies and similar technologies on the Website may constitute “sharing” of Personal Information for cross-context behavioral advertising purposes as defined under applicable state privacy laws, including the CCPA. You may opt out of this sharing by using the “Do Not Sell or Share My Personal Information” link available on the Website or by contacting us at contact@fresco.com.

California residents may have the following rights under the CCPA, subject to applicable exceptions:

• Right to know and access. You may request information about the categories of Personal Information we collect, the purposes for which we use it, the categories of sources and recipients, and the specific pieces of Personal Information we maintain about you.
• Right to delete. You may request that we delete Personal Information that we collected from you, subject to exceptions under applicable law.
• Right to correct. You may request that we correct inaccurate Personal Information that we maintain about you.
• Right to opt out of sale or sharing. You may opt out of the sale of your Personal Information or its sharing for cross-context behavioral advertising.
• Right to limit use and disclosure of Sensitive Personal Information. You may have the right to limit our use and disclosure of “Sensitive Personal Information” (as defined in the CCPA) to the purposes permitted by the CCPA.

To submit a California privacy rights request, please contact us at contact@fresco.com. We may need to verify your identity before completing your request, and we will respond within the time required by applicable law. You may submit a request yourself or through an authorized agent as permitted by applicable law.

Fres-co will not discriminate against you for exercising your CCPA rights. We will not deny you goods or services, charge you different prices or rates, or provide a different level or quality of goods or services because you exercised your rights as provided under the CCPA.

California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) may also permit California residents to request information about certain disclosures of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at contact@fresco.com.

How We Retain Your Data

Fres-co will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with Fres-co’s legal obligations (for example, if we are required to retain your information or data to comply with applicable laws), resolve disputes, and enforce legal agreements and policies.

Fres-co may also retain usage information or data for internal analysis purposes. Usage information or data is generally retained for a shorter period of time, except when this information or data is used to strengthen the security or to improve the functionality of the Website, or we are legally obligated to retain this information or data for longer time periods.

We may also choose to anonymize certain of the information and data provided to Fres-co so that it can no longer be attributed to a user if we would like to retain it for longer periods of time.

The criteria we use to determine retention periods includes: (a) the duration of our relationship with you; (b) whether there is a legal obligation to retain the data; (c) whether retention is advisable in light of our legal position (such as applicable statutes of limitations, litigation, or regulatory investigations); and (d) the sensitivity and nature of the Personal Information.

External Websites

Some hyperlinks and images on the Website may link to third-party websites. You should be aware that these third-party websites are not controlled by Fres-co and are not subject to this Policy. We encourage you to review the privacy policies of any third-party website you visit before providing any Personal Information. Fres-co is not responsible for the privacy practices, content, or security of any third-party websites, applications, or services, even if accessible through a link on the Website.

Children Under the Age of 13

The Website is not intended for children under 13 years of age. No one under 13 years of age may provide any information to or on the Website. We do not knowingly collect Personal Information from children under 13 years of age. If you are under 13 years of age, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received Personal Information from a child under 13 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 years of age, please contact contact@fresco.com.

Changes to this Privacy Policy

It is Fres-co’s policy to post any changes we make to this Policy on this page. If we make material changes to how we treat the Personal Information of users of the Website, we will notify you by email to the primary email address specified in your account. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date active and deliverable email address for you, and for periodically visiting the Website and this Policy to check for any changes.

Contact Information

To ask questions or comment about this Policy and Fres-co’s privacy practices, or to exercise your privacy rights, you may contact Fres-co at: contact@fresco.com, or write to us at: Fres-co System USA, Inc., 3005 State Road, Telford PA 18969-1033, United States of America Attention: Company Secretary.