Solenis Company and its wholly and majority-owned entities (“Solenis Group”, "Company", "we" or "us") takes your data protection seriously. The Solenis Group entity responsible for your personal information will be the member of Solenis Group that originally collects information from or about you. You can find out more about our Group at solenis.com or by contacting us using the information in the Contact Us section of our website.
This Privacy Statement has been issued for compliance with the EU General Data Protection Regulation (GDPR) that went into effect on May 25, 2018, across EEA countries and Switzerland and applies to the personal information Solenis Group obtains through various channels, including websites, online systems and platforms, mobile applications and social media pages that reference this Privacy Statement, and in a course of collection related to sales, marketing, business partner’s, contractors’, vendors’ and suppliers’ engagement (collectively "Instruments”).
This Privacy Statement does not apply to personal information obtained during the recruitment processes and employment relation. This will be subject to the Candidate Privacy Notice (available here) and Fair Processing Notice made available when your personal information are collected by the Company, for example where you send your resume or conclude an employment contract.
This Privacy Statement explains the types of personal information we obtain, how we collect that information, how we may use it, with whom we may share it and what safeguard measurements we take to protect it.
You might find external links to third party websites on our website. This Privacy Statement does not apply to your use of a third party site. We are not responsible for the privacy practices of third parties, which are subject to their respective privacy policies.
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WHAT PERSONAL INFORMATION WE COLLECT, HOW AND WHY WE USE IT
Personal information is any information capable of identifying a natural person, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to their his or her physical, physiological, mental, economic, cultural or social identity. Information is considered personal when it enables anyone to link information to a specific person, even if the person or entity holding that data cannot make that link.
Personal information we collect through the Instruments includes:
We collect the majority of this information from you, for example when you contact us or complete any registration forms on our website. Some information may be generated internally by Solenis, such as a transaction record, phone conversations or may be generated by cookies. In addition, we receive information relating to verification checks (such as your passport and national ID) from our agents, distributors and suppliers in order to undertake anti-money laundering checks or for trade compliance.
How we may use your personal information:
Processing of personal information means undertaking any operation or set of operations that is performed upon personal information, whether or not by automatic means, including, but not limited to collection, recording, organization, storage, access, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, making available, alignment, combination, blocking, deleting, erasure, or destruction.
Depending on our relationship with you, we may use the obtained personal information to undertake the following processing activities:
We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law. In addition, where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.
Legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This includes:
|
What We Use Your Information For |
Legal Basis For Using Personal Data |
Legitimate Interests Legal Basis |
|
To provide customer services support |
Performance of a contract Legitimate interests |
The management of our business |
|
To manage customer relationships |
Performance of a contract Legitimate interests |
The management of our business |
|
To operate our business and comply with our contractual obligations |
Performance of a contract Legitimate interests |
The management of our business |
|
To facilitate marketing communication |
Legitimate interests Consent |
The management of our business |
|
To obtain your feedback |
Legitimate interests |
The management of our business |
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To comply with applicable legal requirements and regulations |
Compliance with legal obligations |
Not applicable |
|
To manage our website and improve your user experience |
Legitimate interests |
To ensure the effective operation of our Site. To ensure that content from our Site is presented in the most effective manner for you and for your computer. If you review or download information on our Site, we track the visit to give us information about which part of the site is frequented. |
In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY section.
We may collect certain aggregate data called web log information (such as your web browser, operating system, pages visited, etc.) and use cookies when you visit many of our web pages. For instance, when you visit one of our websites, our web server will automatically recognize some non-personal information, including but not limited to the date and time you visited our site, the pages you visited, the referrer (the website you came from), the type of browser you are using (e.g., Netscape, Internet Explorer), the type of operating system you are using (e.g., Windows XP or Mac OS), and the domain name and address of your Internet Service Provider (e.g., AOL).
SHARING PERSONAL INFORMATION WITH OTHERS
We may share your personal information within our Solenis Group, where such disclosure is necessary to provide you with our product and/or services or to manage our business operations. Your personal information is accessed by those of our employees with a relevant need to do so in connection with our relationship with you. This includes, without limitation, our sales forces, customer services department, legal, trade compliance, marketing team.
We may also share your personal information with third parties who help manage our business and services’ delivery. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include (i) IT service providers who help manage our IT and back office systems, including administration of Solenis website; (ii) government organizations and agencies, law enforcement, regulators, auditors, global trade compliance and legal advisors to comply with all applicable laws, regulations and rules; (iii) credit checks and debts’ recovery agencies who help us to operate our business and comply with our contractual obligations.
We may share in aggregate, statistical form, non personal information regarding the visitors to our website, traffic patterns, and website usage with our partners, affiliates or advertisers.
If, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.
TRANSFERRING PERSONAL INFORMATION GLOBALLY
We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the EU, including the United States and India that are subject to different standards of data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy and we will take appropriate steps ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests.
Transfers within Solenis Group will be covered by an agreement entered into by members of Solenis Group (an intra group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within Solenis Group.
Where we transfer your personal information outside Solenis Group or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information (e.g., recognized certification schemes like the EU US Privacy Shield and/or EU Model Clauses).
You have a right to Contact Us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
HOW WE PROTECT AND STORE YOUR PERSONAL INFORMATION
Security
We have implemented and maintain appropriate administrative, technical, physical and organizational security measures, policies and procedures consistent with legal requirements where the personal data was obtained that are designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. If you have any questions about security on our website, you can contact us at privacy@solenis.com.
Storing your personal information
We will store your personal information (i) for as long as is reasonably necessary for the purposes for which it was collected pursuant to the provisions of this Privacy Policy and (ii) as long as required by applicable law.
In some circumstances we may store your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, accounting requirements. In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse our website, you are agreeing to our use of cookies. Every time you log onto our website your IP (Internet Protocol) address registers on our servers. Your IP address reveals no information other than the number assigned to you. We do not use this technology to get any personal data against your knowledge or free will. Nor do we use it for any purpose other than to help us monitor traffic on our website or, in the case of possible criminal activity or misuse of our information, to cooperate with law enforcement agencies.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular website. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Cookies may collect personal information about you, such as information about your visit to our website, your country, language and other settings. Cookies allow us to understand who has seen which web pages and advertisements, to determine how frequently particular web pages are visited and to determine the most popular areas of our website. They can also help us to operate our website more efficiently and make your next visit easier. We may use cookies for a variety of purposes, including to help us obtain information about why you visited our website, process your orders, analyze website use patterns to improve how our website can be accessed and provide information, deliver advertising, communications, and content from us specific to your interests as indicated by your use, remember your language and other preferences when using our website, help you obtain information you are looking for within our website, allow for easier product or service registration or warranty notification purposes.
We use traffic log cookies to identify which web pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website experience, by enabling us to monitor which web pages you find useful and which you do not. A cookie does not in any way give us access to your computer or any information about you, other than the data you choose to share with us. In particular, our cookies cannot read data off of your hard drive, cannot read cookie files created by other websites and cannot track any personal information about you. If you erase or reject a cookie, you may still use our website.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of our website.
We use the following cookies: Session cookies, which are temporary cookies that are erased from your computer’s memory when you close your Internet browser or turn your computer off, and Persistent cookies, which exist on your computer’s hard drive until they expire, unless you delete them at an earlier time.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Our online resources do not limit non-identifiable uses of tracking technologies for individual users. We do not collect personal information automatically, but we may combine non-personal information collected automatically (e.g., through cookies) with your previously submitted personal information.
Except for essential cookies, all cookies will expire after 6 months.
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have:
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by using Contact Us. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it. You can also request that we erase your personal information in limited circumstances where: it is no longer needed for the purposes for which it was collected; or you have withdrawn your consent (where the data processing was based on consent); or following a successful right to object; or it has been processed unlawfully; or to comply with a legal obligation to which the Company is subject. We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where: its accuracy is contested, to allow us to verify its accuracy; or the processing is unlawful, but you do not want it erased; or it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal information following a request for restriction, where we have your consent; or to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller, but in each case only where (i) the processing is based on your consent or on the performance of a contract with you; and (ii) the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
This website is not designed for, or directed to, children under the age of 13 and will not knowingly collect personally identifiable information from individuals in this age group. We encourage parents to take an active role in their children's online activities and to talk with their children about disclosing personally identifiable information to websites.
We may amend this Privacy Statement from time to time to keep it up to date with legal requirements and the way we operate our business, and will place any updates on this web page. This Privacy Statement was last updated on December 6, 2019. Please regularly check these pages for the latest version of this Statement. If we make fundamental changes to this Privacy Statement, we will seek to inform you by Statement on our website or email.
If you have any questions, concerns or complaints regarding our compliance with this Privacy Statement, the information we hold about you or if you wish to exercise your rights, we encourage you to complete and submit our Data Request Form or contact our Data Privacy Office at privacy@solenis.com, which is the primary point of contact for all issues arising from this Privacy Statement.
We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.
Solenis International LP
Attn: Data Privacy Office
Information Security Director
3 Beaver Valley Road, Suite 500
Wilmington, DE 19803
United States
Solenis Switzerland GmbH
Attn: Data Privacy Office
EMEA Legal Counsel
Mühlentalstrasse 38
8200 Schaffhausen
Switzerland