Effective Date: February 8, 2020
Leonardo DRS, Inc. and all other covered entities enumerated below (collectively referred to herein as “Leonardo DRS”, “we”, “our” or “us”), recognize the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites. This Privacy Policy applies to data collection by Leonardo DRS and shall apply to your use of the website, www.leonardodrs.com, and other Leonardo DRS-related sites, apps, communications, capabilities and services (“Services”) accessible on or by any top-level Leonardo DRS domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.
Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; and (5) the choices we offer, including how to access and update information. Specifically, our Privacy Policy covers the following topics:
Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.
Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.
If you have any questions or comments about this Privacy Policy, please submit a request to privacy@drs.com.
Our Privacy Policy applies to all of the services offered by Leonardo DRS and its affiliates, and services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
By accessing or using the Sites in any manner, you also agree to be bound by Leonardo DRS’ Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.
We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of personal data include: full name, home address, email address, date of birth, digital identity, such as a login name or handle, information about your device, and certain metadata.
“Sensitive Personal Data” refers to a smaller subset of personal data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation. Leonardo DRS does not collect or use Sensitive Personal Data and asks that you do not provide Sensitive Personal Data to us.
We collect Personal Data in the following ways:
The technologies we use for this automatic data collection may include:
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. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy.
Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
During the last twelve (12) months, we have collected the following categories of personal information from Users.
| Category | Type of Identifiers We Collect | Collected |
|---|---|---|
| Identifiers | Name, billing address, shipping address, email, phone number, zip or postal code, unique personal identifier, Internet Protocol address, and user name and password. | YES |
| Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, address, telephone number, financial account information, education, medical information and employment history. | YES |
| Protected classification characteristics under California or federal law. | Age, racial or ethnic origin, sex, sexual orientation.[A1] | YES |
| Commercial Information | Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, cookies. | YES |
| Professional or employment-related information | Professional or employment-related information, such as work history and prior employer, human resources data and data necessary for benefits and related administrative services. | YES |
We obtain the categories of Personal Data listed above from the following categories of sources:
We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
To inform you about services available from Leonardo DRS;
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our Company and our Users.
We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. We may use your personal information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it.
We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.
Whenever we collect Personal Data from you, we may do so on the following legal bases:
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
We do not share Personal Data with companies, organizations and individuals outside of the Organization unless one of the following circumstances applies:
Your provision of Personal Data is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.
We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Data for one or more business purposes:
We disclose your Personal Data for a business purpose to the following categories of third parties:
We may disclose your Personal Data for legal reasons. Specifically, we will share Personal Data with companies, organizations or individuals outside of Leonardo DRS if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
We may disclose your Personal Data in the event of a business transfer. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset. In the event that Leonardo DRS itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.
In the preceding twelve (12) months, we have not sold any Personal Data.
You may have certain rights relating to your Personal Data, subject to local data protection law. Whenever you use our services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of Personal Data we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that Personal Data we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
If you are a California resident who chooses to exercise your rights, you can:
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
Upon receiving your request, we will confirm receipt of your request by sending you an email. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Data for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
The European Union’s General Data Protection Regulation (“GDPR”),”) may provide you with certain rights in connection with Personal Data you have shared with us. If you are a resident in the European Economic Area, you may have the following rights:
To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws.
You may update or correct information about yourself by making changes in your account, or emailing us at privacy@drs.com. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.
By providing an email address on the Leonardo DRS Sites, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service related notices, or to provide you with information about our events, invitations, or related educational information.
For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.
We currently provide the following opt-out opportunities:
Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change to this Privacy Policy, or to provide you with any service-related notices.
The Sites may contain links to webpages operated by parties other than Leonardo DRS. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Leonardo DRS strongly recommends that each User review the third party’s terms and policies.
We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.
Since we are a global organization, Personal Data and any additional information submitted may be used globally in connection with employment, business processes within Leonardo DRS, or communicating with our clients. Therefore, Personal Data may be transferred to other Leonardo DRS entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.
If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected. It is our policy to, where required by applicable laws, execute a Data Privacy & Data Security Addendum and Standard Contractual Clauses with third parties with whom we may share Personal Data.
Leonardo DRS, Inc. and its U.S. based subsidiaries enumerated below (collectively referred to in this Privacy Shield section as “Leonardo DRS”, “we”, “our” or “us”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States, respectively. Leonardo DRS has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
In compliance with the EU-US Privacy Shield Principles, Leonardo DRS commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Leonardo DRS at: privacy@drs.com.
Leonardo DRS has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.
If your complaint is not satisfactorily addressed, and your inquiry or complaint involves human resources data transferred from the EU in the context of the employment relationship, you may have your complaint considered by an independent recourse mechanism: for EU/EEA Data Subjects, a panel established by the EU data protection authorities (DPA Panel). To do so, you should contact the state or national data protection or labor authority in the jurisdiction where you work. DRS agrees to cooperate with the relevant national DPAs and to comply with the decisions of the DPA Panel. Please do not refer human resources data inquiries or complaints to the BBB EU PRIVACY SHIELD.
If your complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Our organization is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We will disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In addition, our organization retains liability in cases of onward transfers to third parties.
Leonardo DRS maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at privacy@drs.com. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
Leonardo DRS does not track its Users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of personal information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your personal information with third parties for marketing purposes at any time by submitting a request to privacy@drs.com. California Users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section.
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.
If you have any specific questions about this Privacy Policy, you can contact us via email or writing to us at the address below:
Send e-mail to: privacy@drs.com
Send mail to our address:
Leonardo DRS, Inc.
Blake M. Guy
VP, Corporate Counsel
Attn: Privacy Policy Inquiry
2345 Crystal Drive, Suite 1000
Arlington, VA 22202
U.S.A.
U.S. based covered entities: Laurel Technologies Partnership d/b/a DRS Laurel Technologies; DRS Surveillance Support Systems, Inc.; DRS C3 & Aviation Company; DRS Radar Systems, LLC; DRS Naval Power Systems, Inc.; DRS Power Technology, Inc.; Engineered Coil Company d/b/a DRS Marlo Coil; Pivotal Power Inc. d/b/a DRS Pivotal Power; DRS Environmental Systems, Inc.; DRS Sustainment Systems, Inc.; DRS Network & Imaging Systems, LLC; DRS Defense Solutions, LLC; DRS Signal Solutions, Inc., DRS Global Enterprise Solutions, Inc.; DRS Training & Control Systems; LLC, DRS Advanced ISR, LLC, DRS Unmanned Technologies, Inc.; DRS Systems, Inc.; DRS Homeland Security Solutions, Inc.; DRS Systems Management, LLC; Tech-Sym, LLC; DRS International, Inc.; T-S Holding Corporation; ESSI Resources, LLC; Engineered Support Systems, Inc.; Advanced Acoustic Concepts, LLC; Oto Melara North America, LLC; Global Network Services, LLC; Daylight Solutions. Inc. d/b/a DRS Daylight Solutions, Inc.; Daylight Defense, LLC d/b/a DRS Daylight Defense, LLC
Non-U.S. based covered entities: DRS Technologies Canada, Ltd., DRS Technologies Saudi Arabia, LLC, DRS Technologies Canada, Inc., DRS Technologies Verwaltungs GmbH, DRS Technical Services GmbH & Co. KG, 3083683 Nova Scotia Limited