GENERAL PRIVACY POLICY
CHINA ADDENDUM

This China Addendum to the General Privacy Policy (“Policy”) applies to:
(a)Personal Data of residents of People’s Republic of China (“PRC”, for the purpose of this Policy only, PRC means the mainland China, but excludes Hong Kong, Macau, and Taiwan) which is being collected, stored, used, processed, transferred, provided, disclosed or deleted by Lincoln Electric Holdings, Inc. and its majority-owned subsidiaries (hereinafter, “Lincoln Electric” “we”, “our”, “us”); and 
(b)any majority-owned subsidiaries of Lincoln Electric (including but not limited to Lincoln Electric Management (Shanghai) Co., Ltd)  with a  presence in PRC.

Except as stated below, the terms set out in this China Addendum are in addition to the terms set out in the Policy and form an integral part of the Policy. In the event of any conflict or inconsistency between the Policy and the terms of this China Addendum, this China Addendum shall govern and prevail. 
For ease of reference, the following section headings refer to the corresponding sections of the Policy.

III.DEFINITIONS
With respect to the definitions in the Policy, the following words used in this Policy shall have the meaning set forth below. 
1.“Applicable Laws” means the relevant data protection and privacy laws, regulations and other regulatory requirements in the area of privacy, data protection and data security, including the Personal Information Protection Law (“PIPL”) and its accompanying regulations.
2.“Sensitive Personal Data” means certain types of personal data which PIPL and relevant regulations (including but not limited to the Information Security Technology – Personal Information Security Specification) consider to be more sensitive in nature, including but not limited to biometric information, religious beliefs, race or ethnic groups, medical and health data, financial data, location data, as well as all personal information of minors under the age of 14.

IV.KEY DATA PROTECTION PRINCIPLES
B. The Lawfulness, Fairness and Transparency Principle
In PRC, we will obtain prior consent before processing the Data Subject’s Personal Data, or otherwise in accordance with the Applicable Laws, process the Data Subject’s Personal Data without consent based on permissible legal grounds, including but not limited to:
(1)the necessity to process for entering or performance of a contract to which the Data Subject is a party,
(2)the necessity for implementation of human resource management,
(3)the necessity to comply with any legal obligation, 
(4)the necessity for the response to public hygiene emergency or to protect individual’s life, health and property, or 
(5)processing Personal Data disclosed by the Data Subject or other Personal Data that has been legally disclosed within a reasonable scope in accordance with PIPL.

VII.INTERNATIONAL DATA TRANSFER PRACTICES
When we transfer Personal Data from PRC to any country or region outside PRC, we take reasonable and necessary steps to ensure that the processing of Data Subject’s Personal Data by the recipient in compliance with Applicable Laws. 
A.Intra-Group
When we transfer Personal Data to other Lincoln Electric entities established outside PRC, we will do so in accordance with our Intra Group Data Transfer and Processing Agreement including as amended, revised, updated of modified.
B.Third Parties
With respect to transfers of Personal Data from PRC to Third Parties established outside PRC, we will take reasonable steps to use and ensure it is complied with in practice, a data transfer mechanism which is acceptable under the Applicable Laws, such as standard contracts or other situations permitted under the Applicable Laws.

CONTACT DETAILS
Any questions with respect to the Policy or this China Addendum can be addressed to Privacy@lincolnelectric.com.