General Privacy Notice

Solenis Group is the controller of the personal information obtained via our websites, online stores, mobile applications and social media pages (together referred to as our “digital assets”). The relevant Solenis entity that contracts with you or whose premises you visit is the controller of the personal information obtained through any business relationship with us (“business partners”) and when visiting our premises.

We have appointed an Office of Data Privacy (ODP) to oversee our compliance with this Privacy Notice and applicable data protection laws. Our ODP may be contacted using the Contact Us  information below. 

What Personal Information We Collect

We collect personal information of users who interact with our digital assets (whether as a consumer or as a corporate entity), our business partners and visitors to our premises.

You are not under a legal obligation to provide Solenis personal information, such information would be provided at your own volition, however, if you do not provide us with certain information (for example, if you do not provide us with information that is indicated as mandatory on our contact us or registration forms), we may not be able to interact and provide our services to you.

Users interacting with our digital assets

We understand that you expect to learn about Solenis when you visit our websites, use our online stores, platforms and mobile applications or interact with our social media pages. Similarly, we hope to learn about your needs as a user of our digital assets, a potential or current business partner, through your visits.

When you interact with our digital assets, personal information such as:

• Contact information including your name, personal descriptors, home/mobile telephone and fax number, email and postal address,
• job title (position), company you work for, location, VAT number, sector or activity, industry, website URL and how many employees work in your company,
• information used to create your online account such as username, password and security question and answer,
• demographic information,
• information relating to your access to and use of our digital assets that we collect automatically through cookies, web beacons, and other technologies as further described in our Cookie Policy. Such information may include device information, browser type and operating system, pages you view, links you click, your IP address, the length of time you visit or use our digital asset, the referring URL or webpage that led you to our website; and
• other personal information contained in content you submit to us such as through our website contact forms and social media pages.

We collect the majority of this information from you, for example when you contact us or complete any registration forms on our digital assets, you create an account or participate in promotions; you request to receive Solenis marketing; you create and submit content on our digital assets, when you interact with us on social media and with other users of our websites, such as through feedback posting features or you provide your information in order to take steps to enter into a business relationship with us.

Business partners and site visitors

Where you interact with us using our website and social media pages, we will collect personal information as described above. In addition to that, we may collect additional personal information, to facilitate our business relationship with you, such as:

• business contact information, details about your work or profession, information about your company, nationality, location, including signatures,
• customer service and purchase orders’ history,
• government issued identification such as passport or national ID and photographs,
• financial information such as payment, billing address, bank account, credit score, payment card details (i.e., card number, expiration date and security code),
• information collected as part of the products and services we provide to you,
• information about how you use our products and services,
• information we capture through your communications with us e.g. voice recordings of telephone conversations, emails, texts, instant messaging,
• vehicle information, information provided in security ledgers and CCTV images if you visit our offices,
• we may collect limited sensitive personal information (as the term in used under applicable data protection laws), such as information revealing religious or philosophical beliefs and disability information, where necessary to make relevant accommodations (e.g., for accessibility and to accommodate dietary requirements). We only collect and use these types of information if the law permits us to do so,
• details about you that are in public records and available on the internet; and
• any other personal information you voluntarily provide to us.

We collect the majority of this information from you, or if your company provides other information to us in the course of working with us, either directly, as a business partner or as a representative of your company. We may collect information if you attend meetings, events or conferences we organise.

Some information may be generated internally by Solenis, such as transaction records, 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.

We may collect information from other public sources (e.g., your employer’s website) where we believe this is necessary to help manage our relationships with our business partners. To the extent required by applicable laws, we will inform you within the timelines set out by applicable laws, of the collection of your personal information from third party sources.

How We May Use Your Personal Information

Depending on our relationship with you and subject to applicable laws, we may use the obtained personal information to undertake one or more of the processing activities below.

Users interacting with our digital assets

• verify your identity for account creation or business partner onboarding;
• process, evaluate, and respond to your requests, inquiries, and applications;
• manage customer relationships (i.e., including evaluating and responding to your requests, inquiries and applications, creating and administering your account),
• contact you with direct marketing communications. Where required by applicable laws, we will obtain your consent for the processing of your personal information for direct marketing purposes.
• contact you as necessary to enforce Terms and Conditions relating to our services;
• give you access to your user profile app and website history;
• to aggregate and remove personally identifiable aspects of such data in order to perform data analytics services, provided you have given your consent or processing is allowed by law. This will include the creation of pseudonymized and anonymized data;
• protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality; and
• evaluate and improve our digital assets and related services.

Business partners and site visitors

In addition to the purposes for processing your information as a Website User, we also process your information to:

• provide the services that you and/or your company have purchased or licensed from Solenis and to fulfil our obligations under any commercial agreement we have with you or the entity with which you are employed or contracted;
• provide customer services support (i.e., including providing and administering products and services, updates of the status of your order and its fulfilment, sending you products samples, providing expert advice, answering your enquiries),
• operate our business and comply with our contractual obligations (i.e., including performing purchases and payments, auditing, billing, reconciliation and collection activities),
• evaluate, and improve our business (including developing new products and services; managing our communications; performing market research and data analytics; determining and managing the effectiveness of our advertising and marketing; analyzing and customizing our products, services, digital assets and communications;
• facilitate marketing communication (i.e., communicate about our products, services, events, programs and promotions by sending alerts, promotional materials, and other marketing communications),
• obtain your feedback (i.e., conduct and facilitate surveys aiming at evaluation and improvement of our digital assets and services),
• comply with applicable legal requirements and regulations (i.e., to prevent fraud and other unlawful activity, unauthorized transactions, conduct investigations).

We may also 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 data protection laws. In addition, where required by applicable data protection laws, 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.

If you reside in a jurisdiction where your consent is required for the collection, use and disclosure of personal information as set out in this Privacy Notice, by using our digital assets and services, or participating in our events, programs and promotions or communicating personal information to us in connection with our products, services, events, programs and promotions, you are providing your consent to the collection, use and disclosure of personal information as set out in this Privacy Notice.

In some cases, your consent may be “implied” (i.e., your permission is assumed based on your action or inaction at the point of collection, use or sharing of your personal information). If you reside in a jurisdiction where applicable laws require your “explicit” consent for the collection, use and disclosure of personal information as set out in this Privacy Notice, you will be asked to provide your prior and explicit consent.

We will generally obtain consent when we want to use personal information for a new purpose or for a purpose other than those stated at the time of collection in this Privacy Notice or in our the relevant terms and conditions.

Your consent can be withdrawn at any time, except in limited circumstances, including legal or regulatory requirements or as a result of your contractual obligations to us.

Where a legal basis other than consent is available pursuant to applicable laws in the jurisdiction in which you reside, the following table sets out our legal basis for processing your personal information:

Where we rely on our legitimate interest, we take steps to ensure that such interests are not overridden by your interests, fundamental rights or freedoms. In all cases, we will take steps to look after your information in a way that is proportionate and respects your privacy rights. Depending on the jurisdiction in which you reside, you may have a right to object to processing as explained in the LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY section.

If you choose not to provide us with certain personal information, to object to processing, or to withdraw your consent, where a right of withdrawal is available, we may not be able to offer you the products, services, promotions, events, programs or information that you requested or that could be offered to you.

To the extent permitted by Data Privacy Laws and other applicable regulations, 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 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). Where required by applicable laws, we will request your consent before the deployment of cookies and similar technologies on your device. Further information on how we process such data may be found in our Cookie Policy.

To the extent permitted by applicable laws, we may share your personal information within the Solenis Group, where such disclosure is necessary to provide you with our product and/or services or to manage our business operations or comply with applicable laws. 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, IT and back office team, customer services department, legal, trade compliance and marketing team. We do not sell your personal information.

To the extent permitted by the applicable laws, we may also share your personal information with third parties who help manage our business and services delivery, our technology systems and applications, internal procedures, infrastructure, advertising and marketing. These third parties have agreed to confidentiality restrictions. These third parties may include (i) IT service providers who help manage our IT and back office systems, including administration of Solenis business; (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) joint marketing partners and our authorised distributors for the purpose of contacting you for follow-up regarding your requests or to keep you informed of new activities, we may use third party payment processing services in connection with processing your payment of fees and other transactions you initiate on our websites; and (iv) credit checks and debts’ recovery agencies who help us to operate our business and comply with our contractual obligations to the extent it is expressly permitted by applicable laws.

To the extent permitted by applicable laws, we may share in aggregate, statistical form, non-personal information regarding the visits 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 your information to a potential or actual third-party purchaser of our business or assets. To the extent required by applicable laws, we shall obtain your (explicit) consent prior to disclosing your personal information.

Applicable laws may permit or require the sharing of personal information in some circumstances not described above. These circumstances include situations when required by applicable laws or when necessary to protect our group of companies, our employees, our customers, or others, such as when investigating and preventing suspected or actual illegal activities, including fraud, or to assist government and law enforcement agencies. If this happens, we will not share more personal information than is reasonably required to fulfil that particular purpose.

If you reside in a jurisdiction where applicable laws require your explicit consent for sharing of personal information outside the initial and specific purposes, you will be asked to provide a prior and explicit consent.

We operate on a global basis. Accordingly, your personal information may be transferred and stored in countries outside the territory where your personal information was originally collected that are subject to different standards of data protection than the country in which the information was provided. We will transfer the personal information only for the purposes described in this Privacy Notice and we will take appropriate steps to ensure that transfers of personal information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests.

We will transfer your personal information to the regions where Solenis has its operations or where our service providers are located. This includes Asia Pacific, Europe, Middle East and Africa, Latin America and North America.

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., Standard contractual clauses for data transfers between EU and non-EU countries, or other approved transfer mechanisms).

You have a right to obtain more information about the recipients of your personal information and the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above. To exercise this right, please use the Contact Us section below.

Security

We have implemented and maintain appropriate administrative, technical, physical and organizational security measures, policies and procedures consistent with legal requirements where the personal information 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 digital assets, please contact us by using the Contact Us section below.

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 Notice and (ii) as long as required by applicable laws, to resolve disputes, troubleshoot problems or assist with investigations.

To determine the appropriate retention period for personal information, we consider the applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purpose for which we process such data, and whether we can achieve those purposes through other means. We specify the retention periods in our internal policies.

To the extent permitted by applicable laws, 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, to ensure 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.

Subject to your consent where required by applicable laws, we may send you information either via [SMS, push notification or email] that we think may be of interest to you including in relation to news, information and updates about our products and services, events, programs, promotions and personalized information.

Subject to your consent where required by appliable laws and to the extent permitted by applicable laws, we may also share (for gain) such data about you with other entities within the Solenis and third-party groups, so that we or they may send you information, news updates, offers, promotions, and special events, as regards their products and services.

If you prefer not to receive direct marketing communications from us in any form or if you change your mind after providing your consent, you may withdraw your consent by clicking the "unsubscribe" link provided in our communications at any time. Alternatively, you may contact by using Contact Us information below to withdraw your consent.

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. You may choose to disable or delete certain cookies. There are several ways to manage cookies. You can control the use of cookies at the browser level, by instructing your browser to accept cookies, disable cookies or notify you when receiving a new cookie. Please note that if you reject cookies, you may still use our services, but your ability to use some features of our services may be limited. To find out more about cookies, please review our Cookie Policy.

Subject to certain exemptions as prescribed by the applicable laws in the jurisdiction where you reside, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information. Please note that your rights may be restricted in accordance with the relevant laws. Click on the links below to learn more about each right you may have:

• Right to access personal information
• Right to rectify or erase personal information
• Right to restrict the processing of your personal information
• Right to transfer your personal information
• Right to object to the processing of your personal information
• Right to object to how we use your personal information for direct marketing purposes
• Right to a copy of the safeguards for international transfers
• Right to withdraw your consent
• Right to lodge a complaint with your local supervisory authority

Right to Access Personal Information

You have a right to ask us to confirm whether we are processing your personal information and 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 and legal basis for processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred as well as, in case of international transfers, recipients in third countries or international organisations, and if applicable the implemented guarantees or the application of an exception for such international transfers.

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 Solenis 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 defence of legal claims.

Right to Restrict the Processing of Your Personal Information

You can ask us to restrict the processing of 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 (see WHAT PERSONAL INFORMATION WE COLLECT, HOW AND WHY WE USE IT), if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we will 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.

If you would like to update or modify your information or subscription preferences, you may contact us as described in the “Contact Us” section below. On certain Solenis websites and digital assets, you may be able to make these choices directly by logging into your account. You also may unsubscribe from any of our promotional emails by clicking on the “unsubscribe” link in any promotional email you receive from us. Changes made to your profile will be effective once saved into our systems in accordance with our standard procedures.

Right to a Copy of the Safeguards for International Transfers

Where applicable, you can request a copy of, or reference to, the safeguards under which your personal information is transferred outside the territory where your personal information was originally collected. We may obscure certain information contained within data transfer agreements or related documents for reasons of commercial sensitivity.

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.

Right to Withdraw Your Consent

Where applicable, you have a right to withdraw your consent given to us for collecting, using and processing your personal information. Subject to legal and other permissible considerations, we will make every reasonable effort to address your request promptly or inform you if we require further information in order to fulfil your request. To withdraw your consent, please complete and submit our Data Request Form, or use Contact Us, or send an email to privacy@solenis.com. Once we have received notification that you have withdrawn your consent, we will no longer process your personal information and, subject to our retention policy, we will dispose of your personal information securely.

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 applicable laws, for instance if your request is manifestly unfounded or excessive.

You may view and change your data preferences, security settings, and consent preferences in your account dashboard, provided that you set up a user profile on your websites. You can also exercise your rights by using the Contact Us section below. 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 will ensure to respond to your request and comply with your rights (where appropriate), within timelines set by applicable laws. To the extent required by applicable laws and where we have shared your personal information, we will inform any relevant third party of your exercise of certain rights.

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.

Our digital assets are not designed for, or directed to, individuals under the age of 18 and will not knowingly collect personal information from individuals in this age group without prior verifiable consent of their parent or legal guardian and complying with any other legal requirements. We encourage parents to take an active role in their children's online activities and to talk with their children about disclosing personal information to websites. Children should obtain parental or legal guardian consent as per the age threshold established by each country (which, for example in the EU, can be between 13 and 16 years depending on the EU Members State’s law, in Brazil under 12, in the People Republic of China under 14). If we become aware that we have unknowingly collected personal information about a child without verifiable parental or legal guardian consent, we will delete this information from our records or take reasonable steps to de-identify the information.

We may amend this Privacy Notice 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 our websites (and digital assets). Please regularly check our digital assets for the latest version of this Privacy Notice. If we make significant changes to this Privacy Notice, we will seek to inform you by amending this Privacy Notice on our website or email or otherwise provide more prominent notice if required by applicable laws.

We encourage you to review changes to our Privacy Notice, and if you do not agree to the changes in our Privacy Notice, it is your responsibility to stop interacting with us and our digital assets and other services, and/or participating in our programs, events or promotions.

If you reside in a jurisdiction where applicable laws require your consent for changes or updates to this Privacy Notice or for other changes in our approach to data protection, you will be providing your consent by continuing to interact with us or our digital assets, or continuing to participate in our programs, events or promotions. Where your explicit consent is required, you will be asked to provide consent before material changes to this Privacy Notice or other changes in approach to data protection are implemented.