Safe Harbor Privacy Policy.


API Heat Transfer Inc. (the “Company”) protects our employee and customer information, computer networks and systems. Company (hereinafter referred to collectively as “Company”, “we”, “us” or “our”) complies with the Safe Harbor Agreement regarding the transfer of personal data from the European Union (“EU”) to the United States States of America. Accordingly, we follow the Safe Harbor Principles published by the US Department of Commerce (the “Principles”) with respect to all such data. In the event of a conflict between the policies in this Privacy Policy and the Policies, the Policies will control. This Privacy Policy describes our general policies and practices implementing the Principles, including the types of information we collect, how we use it, and the notice and choices available to data subjects regarding our use of that information and their ability to correct it. This Privacy Policy applies to all personal information received by the Company, whether in electronic, paper or oral form.


“Personal Information” or “Information” means information that (1) is transferred from the EU to the US; (2) be recorded in any form; (3) are about or relate to a specific person; and (4) can be linked to that person.

“Sensitive personal data” means personal data that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs or trade union membership or concerns the health of an individual.


The Company informs the individual of the purposes for which it collects and uses the personal information and the types of third parties to which the Company discloses or may disclose such information. The company must provide the individual with the opportunity to limit the use and disclosure of their personal information. The notice will be given in clear and conspicuous language when someone  is first asked to provide personal information to the Company, or as soon as possible thereafter,  but in any case before the Company uses the information for any purpose other than that for which it is intended where they were originally collected, used or disclosed.


The Company offers individuals the opportunity to choose whether to have their personal information (1) disclosed to third parties or (2) used for a purpose other than that for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, the Company provides individuals the opportunity to consent or expressly object (opt-out) to the disclosure of the information for a purpose other than that for which it was originally collected or subsequently authorized by the individual. The Company treats sensitive personal information received from an individual in the same manner as the individual would treat and identify it as sensitive personal information.


Before the company passes on personal data to third parties, it must inform the data subject about this transfer and give them the opportunity to decide against such transfer (opt-out). The Company will ensure that all third parties to whom personal information may be disclosed adhere to the Principles or are subject to laws that provide the same level of data protection as required by the Principles and undertake in writing to provide an adequate level of data protection offer.


The Company takes reasonable measures to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Company has put in place appropriate physical, electronic and managerial procedures to protect and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. The Company cannot guarantee the security of any information on the Internet or during transmission over the Internet.


The Company will only process personal data in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by the individual. To the extent necessary for these purposes, the Company will take reasonable steps to ensure that the personal information is accurate, complete, current and reliable for its intended use.


The Company must provide an individual with access to their personal data and the opportunity to correct, amend or delete inaccurate data, unless the burden or cost of providing access would be disproportionate to the risks to the privacy of the person in the case in question or the rights of persons other than the person would be violated.


The Company uses a self-assessment approach to ensure compliance with this Privacy Policy and regularly reviews whether the Policy is accurate, comprehensive for the information intended to be covered, clearly visible, fully implemented and accessible, and consistent with the Principles. We encourage interested individuals to raise any concerns using the contact information provided, and we will investigate and attempt to resolve all complaints and disputes regarding the use and disclosure of personal information in accordance with the Principles.

The company has trained the employees involved in the transmission of information for the EU. If employees do not follow this policy, appropriate disciplinary action will follow.

The Company will periodically review this policy and make appropriate changes to ensure compliance.

If a complaint or dispute cannot be resolved through our internal process, we will agree to have the dispute resolved by an  appropriate independent person or institution .


This Privacy Policy may be changed from time to time in accordance with the requirements of the Safe Harbor Policy. We will post any revised policy on this website.


The Company is committed to following the principles for all personal data under the Safe Harbor Agreement. However, certain information is subject to Company policies that may differ in some respects from the general policies set forth in this Privacy Policy.


Questions, comments or complaints regarding the Company’s Safe Harbor policy or data collection and processing practices may be directed by mail or email to:

Theresa Jensen
Attn: Human Resources Department
2777 Walden Avenue
Buffalo, NY 14225