Dauch_Responsible Minerals Sourcing Policy Statement
AAM Conflict Minerals Reporting Template 2024
Dauch - Website Privacy Notice
Last Updated: 2 February 2026
Dauch Corporation (“Dauch”, “we”, “our”, “us”) is committed to protecting and respecting your privacy. We are a public corporation established in Delaware with its principal place of business at One Dauch Drive, Detroit, MI 48211-1198, United States, and for the purpose of applicable data protection laws, we are the data controller.
This Privacy Notice sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of this website (our “Website”).
Please read this Privacy Notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. This Privacy Notice supplements any other privacy related notices we may provide to you from time to time, and is not intended to override them.
1. THE INFORMATION WE COLLECT
Information you give to us
You may provide some or all of the following personal data to us by interacting with our Website:
- Your name,
- Contact details (such as mailing addresses, email addresses or phone number), and
- Any other information you choose to include in communications with us.
Information we collect automatically
When you visit our Website, we automatically collect the information sent to us by your computer, mobile phone, or other device. This information includes:
- your IP address;
- device information including, but not limited to, name and type of operating system;
- mobile network information;
- standard web information such as your browser type and the pages you access on our Website;
- transaction information (but not payment card or account details), including device information, transaction details, and IP address;
- location information, such as approximate location;
- security information including a list of certain installed software, device and internet connection information, and available space on the device.
Information we collect from third parties
We may employ third-party companies to perform services or functions on our behalf (data processors). These companies may require access to personal data in order to perform their functions, but may not use it for other purposes.
2. HOW DO WE USE YOUR INFORMATION?
We process your personal data for the following purposes:
- Provide you with our Website functionality and services;
- Generate statistics and measure site activity for the purpose of continuously improving the Website; and
- Send electronic newsletters or other communications you registered for.
We rely on the following legal bases to process your personal data:
- In certain situations, we might obtain your consent to process your personal data;
- If a contract between us exists, we may use your personal data for the performance of this contract;
- We will also use your personal data to pursue our legitimate interests (in particular to administer the Website for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis, maintain the safety and security of the Website and business, and to personalize our Website for you and your device);
- In addition, we will use some or all of the above information to comply with any applicable legal obligations, to enforce any applicable terms and conditions and/or terms of service, and to protect or defend the Website, our rights, the rights of our users, or others.
3. HOW THE COMPANY SHARES YOUR INFORMATION
We do not use or share your personal data with others except as described in this Privacy Notice. In certain circumstances, we will share your information with third parties with your consent, as necessary, or as otherwise required or permitted by law. Specifically, we share your personal data:
- With service providers and vendors. Such third parties include: (i) data analytics vendors; (ii) security vendors; and (iii) website hosting vendors. These service providers assist us with many different functions and tasks, such as providing data storage and disaster recovery services and communicating with you.
- With professional advisors, in our legitimate interests or as required by law. As necessary, we will share your personal data with professional advisors such as auditors, law firms, or accounting firms. We have a legitimate interest in using professional advisors in the course of our business activities. In some cases, cooperation with such advisors might also be required by law.
- For legal and security reasons and to protect our services and business, in our legitimate interests or as required by law. We will share your personal data with regulators, law enforcement agencies, public authorities, or any other relevant organisations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements. The purposes listed under (iii), (iv), and (v) correspond to respective legitimate interests on our side.
- With our affiliates, in our legitimate interests. We may share your personal data with companies within our corporate family. We have a legitimate interest in cooperating with other group companies.
- In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation, in our legitimate interests. We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets. We have a legitimate interest in sharing relevant information in the course of relevant business transactions.
4. THIRD PARTY WEBSITES AND LINKS
5. CHILDREN'S PRIVACY
Children under the age of 13 are not permitted to use the Website, and we do not seek or knowingly collect any personal data about children under 13 years of age. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal data, you may contact us using the below information to request that it be deleted.
6. WHERE WE STORE YOUR INFORMATION
Personal data that we collect from you will be processed and stored primarily in the United States.
If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), your data will be transferred to and stored at countries outside the EEA and the UK. Your personal data is also processed by staff operating outside the EEA or the UK who work for us or one of our third-party service providers or partners. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice.
For any transfers of personal data from within the EEA or the UK to countries outside the EEA or the UK, the data transfer will be carried out either under the EU-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework, or pursuant to the EU Standard Contractual Clauses or the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact us at privacyofficer@dauch.com should you wish to examine a copy of the EU Standard Contractual Clauses or the UK International Data Transfer Addendum to the EU Standard Contractual Clauses.
7. DATA SECURITY
Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Website or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.
8. HOW LONG DO WE STORE YOUR PERSONAL DATA?
As a general rule, we will retain your data as long as they are necessary in relation to the purposes for which they were collected or otherwise processed. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you with the services, comply with our legal obligations, prevent harm, promote safety, security and integrity, protect ourselves, resolve disputes or enforce our terms and conditions, other applicable terms of service, and our policies.
9. CALIFORNIA RESIDENTS
This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).
In the preceding 12 months, when you interacted with our Website, we collected and disclosed the following categories of personal data
- Identifiers, such as name, e-mail address and IP address.
- Personal information categories listed in the California Customer Records statute such as name, address and telephone number.
- Internet or other similar network activity such as information regarding your interaction with the Website, such as transaction information (but no payment card or account details) and security information.
- Geolocation data such as IP address.
We disclose your information to the categories of third parties described in the section above, How the Company Shares Your Information. The specific business or commercial purposes for which we collect your personal information and the categories of sources from which we collect your personal data are described in the sections above, The Information We Collect and How Do We Use Your Information?. We only use and disclose sensitive personal information for the purposes specified in the CCPA. The criteria we use to determine how long to retain your personal information is described in the section above, How Long Do We Store Your Personal Data?
We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.
10. YOUR RIGHTS
If you are located in the EEA or the UK, you have certain rights in relation to your personal data:
- Access: You have the right to access personal data we hold about you, how we use it, and who we share it with.
- Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
- Correction: You have the right to correct any of your personal data we hold that is inaccurate.
- Erasure: In certain circumstances, you have the right to delete the personal data we hold about you.
- Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.
- Objection: You have the right to object to our processing of your personal data.
- Complaints: You have the right to make a complaint to us about our processing of your personal data – please see Section 8 for further information.
- Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by emailing us at privacyofficer@dauch.com.
If you are a resident of California, you may have the rights listed below in relation to your personal data.
- Know: You may have the right to request the personal data we hold about you, and to obtain details about how we use and share your information, and with whom we share or have shared it in the past.
- Deletion: You may have the right to request that we delete personal data we hold about you.
- Correction: You may have the right to request that we correct inaccurate personal data we hold about you.
Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.
To exercise any of these rights, you can contact privacyofficer@dauch.com or toll-free at (877) 846-8912. We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). We will not discriminate against you for exercising any of these rights. Further information may be needed to verify your identity before exercising these rights, such as your email address, date of birth or government-issued ID. If you are a California resident, you may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
11. COMPLAINTS
If you have complaints about how we process your personal data, please contact our Privacy Officer at privacyofficer@dauch.com.
If you think we have infringed data protection laws, you can file a claim with the Information Commissioner’s Office (if you are in the UK) or the data protection supervisory authority in the EEA country in which you live or work or where you think we have infringed data protection laws.
12. CONTACT US
We welcome your questions, comments, and concerns about this Privacy Notice or your personal data. Please contact us at privacyofficer@dauch.com or toll-free at (877) 846-8912.
We change our Privacy Notice from time to time. Updates to our Privacy Notice will apply only to information collected after the date of the change. We will note on our Website when our Privacy Notice has been updated. Please check the Website regularly for notices of changes to our Privacy Notice. If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Website, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Website.