Privacy Policy

CIRCOR International, Inc.
Privacy Shield Privacy Policy
For Human Resources Data

CIRCOR International, Inc.; CIRCOR Aerospace, Inc.; CIRCOR Energy Products, Inc.; and CIRCOR Pumps North America, LLC (collectively, the “Company”) comply with the EU-U.S.
Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union (“EU”) to the United States (the “Privacy Shield Principles”). The Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles when processing Personal Data received from the EU that relates to current or former employees located in the EU. For purposes of this Policy, “Personal Data” means any information received by the Company from the EU, recorded in any form, which relates to an individual who is identified in, or identifiable based on, the Personal Data received. More information about the Privacy Shield Framework as well as the Company’s certification on the Privacy Shield List is available at

The Company’s Collection And Use Of Personal Data
The Company receives the Personal Data of current and former employees located in the EU to administer the employment relationship. This Personal Data consists largely of information provided during the hiring process, for example, in resumes and completed job applications1; information provided by employees, such as personal contact information and self-evaluations; and information created by the Company or its affiliates to administer the employment relationship, such as business contact information, job title, job category, job status, information needed to implement employee salary increases and bonuses, and performance reviews.

The Company collects and uses Personal Data to facilitate the administration of the employment relationship between its EU subsidiaries and their current and former employees and to carry out human resources activities affecting those individuals. These purposes include, without limitation, workforce management, including preparing headcount reports; administering performance appraisals; engaging in succession planning; administering training of employees; managing employee benefits, including, but not limited to, stock option plans; managing employee compensation and reimbursement; administering physical and information systems security, providing help desk support and managing internal contact lists and directories as well as emergency contact information; maintaining workplace safety; making travel arrangements; addressing various legal obligations related to the employment relationship, including compliance audits, internal investigations and discovery obligations in civil litigation; and administering the Company’s ethics and compliance processes.

The Company’s Disclosure Of Personal Data
The Company may disclose the Personal Data of current and former employees located in the EU, subject to written agreement, to authorized service providers who provide services related to the administration of the employment relationship. The Company also may disclose employees’ Personal Data to corporate affiliates for internal employment administration purposes, such as to administer access to physical facilities and information systems and for succession planning. The Company may be liable for the onward transfer of Personal Data to third parties.

The Company may be required to disclose, and may disclose, Personal Data in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements.

Choices For Limiting The Use And Disclosure Of Personal Data
For its current and former employees in the EU whose Personal Data has been transferred to the United States, the Company will provide the opportunity to opt out from: (a) the disclosure of their Personal Data to a non-agent third party; and (b) the use of their Personal Data for purpose(s) that are materially different from the purpose(s) for which the Personal Data was originally collected or subsequently authorized by the individual. The Company will provide employees with clear, conspicuous and readily available mechanisms to exercise their choices should such circumstances arise. Individuals who otherwise wish to limit the use or disclosure of their Personal Data should submit their request to

Individuals’ Right To Access And Correct Their Personal Data
Upon request and in accordance with applicable local law, the Company will grant current and former employees access to their Personal Data and will permit them to correct, amend or delete Personal Data that is inaccurate or incomplete or that is being processed in violation of the Privacy Shield Principles. Current and former employees who wish to exercise these rights can do so by contacting the Company’s Privacy Governance Committee through the following email address: For security purposes, the Company may require verification of the requester’s identity before providing access to Personal Data.

More Information And What To Do If You Have a Complaint
Current and former employees can contact the Company with any inquiries about the Privacy Shield or the processing of their Personal Data at

In compliance with the Privacy Shield Principles, the Company commits to resolve complaints about its collection or use of the Personal Data of current and former employees located in the EU. Any current or former employee who has a complaint should submit the complaint to The Company will promptly investigate, and attempt to resolve, such complaints in accordance with this Policy and the Privacy Shield Principles. Any current or former employee who is not satisfied with the internal resolution of a complaint may seek redress with the national data protection or labor authority in the country where the individual resides or works. The Company commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to human resources data transferred from the EU in the context of the employment relationship. The Federal Trade Commission has jurisdiction over the Company’s compliance with the Privacy Shield.

1 Job applications previously submitted by EU employees will be transferred to the U.S. only in limited circumstances, such as for individuals in management-level positions.