Privacy Notice

Effective May 23, 2022

Last Updated June 26, 2026

We at Sperry Marine (“we”, “us”, “our”, “Sperry Marine”) respect your concerns about privacy. Sperry Marine provides various programs, features and services. Some of our services adopt different privacy statements or notices that supplement this statement in accordance with local or regional privacy laws. This Privacy Notice (“Notice”) is intended to provide you with the information that you need to understand how we may process your Personal Information.

This Notice is supplemented by sections which provide further information related to the processing of your information depending on the relationship or interaction you may have with us. Please be aware that not all sections will be relevant to you. The Data Controller may vary depending on how you interact with Sperry Marine, our affiliated entities, and our services. If you are unsure which Data Controller controls your data or if you have any questions, please do not hesitate to contact us using one of the means provided in the “How to Contact Us” section below.

This Notice describes the types of Personal Information we may collect, how we use the information, with whom we share it and the choices available to individuals regarding our use of the information. We also describe the measures we take to protect the security of the information and how individuals can contact us about our privacy practices.

This Notice uses certain terms that have the meaning given to them in the California privacy laws. This notice is also applicable to California residents employed by Sperry Marine.

Information We Collect/Obtain
How We Use the Information We Collect
Information We Share
Your Rights and Choices
Data Transfer
How We Protect Personal Information
Data Retention
Links To Other Websites
Updates To Our Online Privacy Notice
How to Contact Us

Information We Collect /Obtain

Sperry Marine may collect information directly from you or from third parties where we are offering services. The following categories of Personal Information are common examples of information we may obtain about you. The following examples are not exhaustive and are intended to illustrate the categories and types of information we process:

Contact Information (such as name, postal address, telephone number and email address)
Transaction Information (such as details of your inquiry to Sperry Marine, marketing preferences)
Professional or Employment Information (such as title, division and employer, including military rank)
Log-in Credentials (such as username, password, time and date of login)
Sensory Information (such as audio, electronic, visual, thermal, and similar information)
Other Personal Information found in content that users provide
Inferences: inferences about customers and suppliers, including their representatives, and employees, and job applicants drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes

Of the Personal Information collected, we may collect the following categories of Sensitive Personal Information which may have special protections under the laws of your region:

Log-in Credentials; (such as username, password, time and date of login
Identifying Information (such as including ethnicity, citizenship, gender, disability, military and veteran status)

How We Use the Information We Collect

We may use the above categories of Personal Information and Sensitive Personal Information for certain business and/or commercial purposes, including as described in this table:

Purposes	Categories of Personal Information	Legal Basis
To provide products and services	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials; Sensory Information	Consent Necessary for the performance of a contract that governs the services we provide Necessary for our legitimate interests
To provide you with support and to respond to your requests or inquiries, including to investigate and address any concerns	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials; Sensory Information	Consent Necessary for the performance of a contract that governs the services we provide Necessary for our legitimate interests
To operate, evaluate and optimize our business and strategies (including developing new products and services; enhancing and improving our products and services; managing our communications and business relationships; identifying business opportunities and creating profiles to better understand your needs and interests; analyzing our products, services and communications; and performing accounting, auditing and other internal functions)	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials; Inferences	Necessary for our legitimate interests
To perform data analyses (including analytics, anonymization and aggregation of Personal Information)	Contact Information; Transaction Information; Professional or Employment Information	Necessary for our legitimate interests
To protect against, identify, and prevent cybersecurity and other security events, espionage, fraud and other unlawful activity, claims and other liabilities; and prosecuting those responsible	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials	Necessary for our legitimate interests
To comply with Sperry Marine policies	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials	Necessary for our legitimate interests
To comply with and enforce applicable legal or regulatory requirements, contractual obligations, relevant industry standards;	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials	Necessary for us to comply with a legal, obligation
To respond to law enforcement requests	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials	Necessary for us to comply with a legal obligation
To communicate with you about, and administer your participation in, special events, programs, offers, surveys and market research	Contact Information; Transaction Information; Professional or Employment Information	Consent Necessary for our legitimate interests
To send you promotional materials or other communications	Contact Information; Transaction Information; Professional or Employment Information	Consent Necessary for our legitimate interests
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred	Contact Information; Transaction Information; Professional or Employment Information	Necessary for our legitimate interests

Information We Share

Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your Personal Information, as described in “Information We Collect” and “How We Use the Information We Collect” sections above, during the 12-month period prior to the effective date of this Statement.

For Personal Information collected during such timeframe, we describe below:

The categories of sources from which we may have obtained the Personal Information, the categories of Personal Information we may have disclosed for a business purpose and the categories of persons to whom we may have disclosed such information, and the categories of Personal Information we may have shared to a third party, if any.

Sources of Personal Information

We may have obtained Personal Information about you from various sources, including as described below.

Categories of Sources of Data Collection	Categories of Personal Information
Directly from you (such as when you provide identifiers to gain access to one of our facilities)	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials; Sensory Information; Employee Information
Our affiliated entities	Contact Information; Transaction Information; Professional or Employment Information
Vendors who provide services on our behalf	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials; Employee Information
Our customers and business partners (such as subcontractors and suppliers)	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials
Government agencies, law enforcement, courts and regulators	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials
Cybersecurity information sharing resources	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials
Social networking services	Contact Information; Transaction Information; Professional or Employment Information
Public databases	Contact Information; Professional or Employment Information

Disclosure of Personal Information for a Business Purpose

We may have disclosed certain categories of Personal Information to certain categories of Recipients for a business purpose, including as described below.

Categories of Recipients	Categories of Personal Information
Our parent organization and its other subsidiaries	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials
Vendors who provide services on our behalf	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials
Our customers and business partners (such as subcontractors and suppliers)	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials
Participants in cybersecurity information resources (when related to a cyber threat indicator)	Contact Information; Transaction Information; Professional or Employment Information
Government agencies, law enforcement, courts and regulators	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials
Other parties in the event of a corporate transaction, such as an acquisition, merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business or assets, whether as a going concern or as part of a reorganization, spin-off, dissolution, bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred	Contact Information; Transaction Information; Professional or Employment Information; Log-in Credentials

For a list of relevant service providers, please contact us using one of the means identified in the “How to Contact Us” section below for more information.

Sale or Sharing of Personal Information

Except as described in this Notice, we do not sell or otherwise disclose Personal Information we collect about you to third parties or in exchange for monetary or other valuable consideration. We may also share Personal Information with service providers who perform services on our behalf based on our instructions. We may share certain Personal Information with our affiliates for the purposes described in this Notice.

Your Rights and Choices

We offer you certain choices in connection with the Personal Information we collect from you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as indicated in the “How To Contact Us” section of this Notice.

To the extent provided by the laws of your jurisdiction, you may request access to, rectification of, addition to, and erasure of the Personal Information we maintain about you. Where our processing of your Personal Information is reliant on your consent, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

In the United Kingdom, If you are dissatisfied with our response, you have the right to raise a data protection complaint directly with us in the first instance. We will acknowledge your complaint within 30 days and respond without undue delay. If you remain dissatisfied following our response, you may then escalate your complaint to the ICO: Make a complaint about how an organisation has used your personal information | ICO.

If you feel that your rights and choices are not adequately addressed, you maintain the right to lodge a complaint with a supervisory authority.

To exercise your rights as a data subject or consumer, please click the link below:

Global Data Subject Access Form

Global Privacy Controls

We generally recognise commercially recognised opt-out preference signals (e.g. Global Privacy Controls (GPC)). To the extent that we are able to recognise these signals and the technologies are legally sufficient, we will process these signals as requests to opt-out of sale, sharing or processing for the purposes of targeted advertising. Recognition of such signals may apply only to the specific device and/or browser that communicates the signal and may not cross over to all devices/browsers you use to access the services which we provide. You may select and install a mechanism or technology to send opt-out preference signals of your choice per the provider's instructions.

How to Submit a Request

To exercise your rights, you must submit a verifiable request to us using one of the means identified in the “How To Contact Us” section below. Only you, or someone legally authorized to act on your behalf, may make a verifiable request for your Personal Information. If you are a California Resident you may only submit a request twice within a 12-month period. We do not typically charge a fee to process a verifiable request. If we determine that your request warrants a fee due to its nature and the existence of a lawful basis for charging such a fee, we will explain our rationale for assessing a fee and provide you with a cost estimate before completing your request.

To exercise your rights as a data subject or consumer, please click the link below:

Global Data Subject Access Form

Data Transfer

We may transfer the Personal Information we collect about you to recipients in countries other than the country in which the information originally was collected, including the U.S. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your Personal Information to recipients in other countries (such as the U.S.), we will protect that information as described in this Notice.

If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, we comply with applicable legal requirements by protecting your Personal Information when it is transferred to countries outside of the EEA, the United Kingdom or Switzerland that have not been recognized by either the European Commission or the United Kingdom as providing an adequate level of data protection. The steps we take include concluding data transfer agreements incorporating the European Commission’s Standard Contractual Clauses or the United Kingdom’s International Data Transfer Agreement with the relevant data recipient or ensuring that the data recipient has implemented Binding Corporate Rules. You may obtain a copy of these agreements by contacting us as indicated in the “How To Contact Us” Section below.

Further, Sperry Marine and our parent organisation comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Our parent organisation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Our parent organisation has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. View our EU-U.S. and Swiss-U.S. Data Privacy Framework Privacy Notices and our participating US subsidiaries. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Personal information that is shared with third party processors in Canada is done so under the adequacy decision granted by the European Commission in 2001 declaring that Canada’s Personal Information Protection and Electronic Documents Act (the “PIPEDA”) provided an adequate level of protection for personal data transferred from the EU to organizations in Canada.

If you are located outside the EEA, the United Kingdom or Switzerland, you acknowledge that we may transfer the information to countries in which the laws may not offer the same level of data protection as the laws of your own country.

How We Protect Personal Information

We maintain appropriate technical and organizational safeguards designed to protect your Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We also require our service providers with whom we share your Personal Information to do the same.

Data Retention

Sperry Marine will retain your Personal Information only for a period reasonably necessary to fulfil the legitimate purposes for which it was collected, in alignment with our business needs, unless a longer retention period is required or permitted by applicable law, regulation or contractual obligation. When determining how long to retain Personal Information, we take into account the necessity of the Personal Information for the provision of our purposes, applicable laws and regulations, and compliance with our legal, regulatory or contractual obligations. We may retain data to establish, exercise or defend against legal claims. When retention of the Personal Information is no longer necessary for a legitimate purpose, the information will be deleted or anonymized.

Links To Other Websites

Our Sites may provide links to third-party websites for your convenience and information. These websites may operate independently from Sperry Marine and our parent organisation. This General Notice only applies to Personal Information collected on this website and does not apply to your use of a third-party site. Linked sites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites, even though you may enter that site directly from visiting our website.

Updates To Our Online Privacy Notice

This General Notice may be updated periodically, and without prior notice to you, to reflect changes in our Personal Information practices. We will post the updated version on our website and indicate at the top of the notice when it was most recently updated.

How To Contact Us

If you have any questions or comments about this Notice or the ways in which we collect, use and protect your Personal Information described here. You may contact our Data Protection Officer Dr Axel Von Walter at Privacy@sperrymarine.com , or if you wish to exercise the rights and choices you may have available under applicable law, or want to request this Notice in an alternate form, please contact us using one of the methods described below:

Global Data Subject Access Form: Click here

Email: Privacy@Sperrymarine.com

Postal Mail:

Sperry Marine
HR Department
Burlington House 118 Burlington Road
New Malden KT3 4NR
United Kingdom

Subsidiaries/Affiliates

Sperry Marine B.V.
Sperry Marine B.V. (Germany Branch)
Sperry Marine B.V. (Denmark Branch)
Sperry Marine B.V. (Belgium Branch)
Sperry Marine B.V. (UK Branch)
Northrop Grumman Canada (2004) Inc. DBA Sperry Marine Canada
Northrop Grumman Systems Corporation DBA Sperry Marine
Northrop Grumman International Trading Inc.
Sperry Marine Korea YCH
Sperry Marine (S) PTE. LTD.
Northrop Grumman Sperry Marine Trading (Shanghai) Company LTD.