CRC Industries – Europe Privacy Notice

Effective Date: May 25th 2018


CRC Industries Europe BVBA ("CRC Belgium") and CRC Industries UK Limited, CRC Industries France S.A.S., CRC Industries Deutschland GmbH, CRC Industries Iberia, S.L.U., CRC Industries Sweden AB, and CRC Industries Finland OY (collectively, with CRC Belgium,"CRC EU," we," "us," or "our") are committed to respecting your privacy. In support of our commitment, we developed this privacy notice to be transparent about the data we collect about you and how it is used and shared, as well as the choices and rights available to you with respect to the data we maintain about you. This privacy notice applies to:



CRC Belgium will be the controller of your personal data and responsible for the processing of such data by or on behalf of CRC EU, and each other CRC EU company will be joint controllers of such data.


  1. Information We Collect and How We Use It

    Collection and Use of Personal Data

    Personal Data Collected

    We collect information that can be used to identify or contact a person (we refer to this as "personal data"). Personal data includes information that does not directly identify you by name or include your contact information, but which may be used to identify that a specific computer or device has accessed our website and online services and which if combined with certain other information could be used to identify you. The types of personal data we collect and process include:


    • Full name

    • Contact information (work or home postal address; work, mobile or home telephone number; work or personal email address)

    • Employer or agency, industry, and job title

    • Delivery and payment information

    • Survey response data

    • Education and experience information (CV information; professional experience; employment history; education; certifications; personal interests)

    • Engagement information (order, engagement and collaboration history; contractual relationship information; inquiries, feedback and comments; content contained in email exchanges with us)

    • IP address

    • Log data

    • Cookie data (including third-party cookies and relate data)

    • Location data

    • Social media use and utilization



    We collect personal data when you provide it to us directly (e.g., when you submit a contact form through our website or provide us with your business card at a trade show); when generated by your activity on our website and online services (e.g., the amount of time spent on a particular page of our website); when shared with us by our business partners (e.g.,

    email marketing vendors, trade show sponsors, or HR staffing agencies); and when available through publicly-available sources (e.g., information shared by you on LinkedIn).


    Use of Personal Data

    We collect, use, store, organize, structure, disclose, or otherwise process personal data as described below:



    Please see our Notice on Use of Cookies and Similar Technologies to learn more about our collection and use of non- personal data.

    Combining Information

    Where permitted by law, we may combine the personal data you provide to us through the website and online services with information we collect through other CRC EU website and online services, our offline records, and information provided to us by third parties. Where permitted by law and feasible, we may also combine your personal data with information collected through your use of the website and online services (such as log data, location data, and cookie data), in which case we will treat any information that is combined or associated with your personal data as personal data for as long as it can reasonably be linked with your personal data. We use this consolidated information to improve our website and online services and product offerings, enhance our marketing and research activities, communicate information to you, and for any other legitimate purpose described in this privacy notice.

  2. How Personal Data is Shared and Transferred

    Personal Data Shared with Third Parties

    We disclose your personal data to third parties who provide us with various business services (e.g., monitoring and maintaining our website or internal business applications, preparing newsletters and mailings, and payments of commissions or other amounts). These service providers and contractors are restricted from using this personal data in any way other than to provide services on our behalf and subject to our documented instructions only.


    We may also share your personal data with our affiliates (e.g., for internal administrative purposes or where a CRC EU affiliate supports one of our business functions). The names and locations of such affiliates can be found here and here.


    We may also partner with other companies to provide you with products, services, or content on a joint or 'co-branded' basis. If we offer co-branded products, services or content, you may see both our logo and the logo of the co-branded partner. To access or use co-branded products, services or content, you may have to provide certain requested information which may be shared with our co-branded partners. You should read the individual privacy policies and terms of use of our co-branded partners, as these may differ in some respects from this privacy notice. You can always opt-out of sharing your personal data with a co-branded partner by choosing not to use the product, service or content provided.


    We may also disclose information we collect to legal counsel, law enforcement, and other appropriate authorities in special cases, including: (i) when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interference with our rights and property or those of any other person; or (ii) when we believe that it is required by applicable laws, court orders, or government regulations.


    If all or part of CRC EU is merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. Your information may also be included among the assets affected by financing agreements undertaken by us.


    International Transfers of Personal Data

    In some instances, the service providers, business partners, CRC EU affiliates, and others that we share personal data with are in other countries. The level of protection for your personal data in these other countries may not be the same as the level of protection in your country. In these cases, we protect any information transferred to third countries using appropriate safeguards, such as contractual clauses approved by relevant supervisory authorities (where required and applicable). All CRC EU affiliates outside of the European Union that access or receive your personal data are subject to data protection contracts approved by the European Commission and that impose on such affiliates a level of protection for your personal data equivalent to European data protection requirements.


    In any event, we only share personal data with our affiliates and third parties performing services on our behalf if such affiliates and third parties provide sufficient guarantees to implement appropriate technical and organizational measures in such a manner that the processing they conduct will meet the requirements of applicable law and ensure the protection of your personal data.


  3. Your Rights

    You have various rights with respect to the collection, use, transfer and processing of your personal data, as described below. However, we reserve the right to limit these rights at any time where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us using the applicable contact information below.

    Access Right

    You have the right to obtain confirmation as to whether or not your personal data is being processed by us. Where we are processing your personal data, you have the right to access the data and to obtain certain information about the processing of such data.


    Right to Rectification

    You have the right to obtain rectification of any personal data that is inaccurate or incomplete, including by means of providing a supplementary statement.


    Right to Erasure

    You have the right to have your personal data erased where one of the following applies:



    Right Not to Be Subject to Solely Automated Decisions

    You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you, unless permitted under applicable law.


    Right to Submit a Complaint to Supervisory Authorities

    You have the right to lodge a complaint with an applicable data protection authority. You have the right to lodge such a compliant in the European country of your habitual residence, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes applicable EU data protection laws. A list of all European supervisory authorities and their respective contact information is available here.


  4. How We Protect Personal Data

    We provide reasonable technical, physical, and organizational safeguards to protect your personal data, including safeguards designed to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed which may lead to physical, material or non-material damage. To the extent appropriate or required by applicable law, these security measures include:


  5. Retention and Deletion of Personal Data

    We implement and maintain reasonable restrictions on the retention of personal data and generally disposes of such personal data once it is no longer necessary for the purposes for which it was collected or further processed. However, we may continue to store archived copies of your personal data for legitimate business purposes and as necessary to comply with applicable law. In addition, we may continue to store anonymous, aggregated or anonymized information for any legitimate business use described in this privacy notice.


  6. Links to Third-Party Websites

    This privacy notice only applies to CRC EU websites and online services that link to this privacy notice. However, our website and online services may contain links to third-party sites or services (e.g., websites relating to industry trade shows and conferences). We do not endorse and are not responsible for the content of third-party websites or resources, and our privacy notice does not apply to any sites that are not controlled by us, even if you access such sites via a link on our website and online services. You should review the privacy policies and terms of use of any third-party site before providing any information to the controller of such site.


  7. How to Contact Us

    If you have any questions about this privacy notice, our use of your personal data, or your rights with respect to such use, you may contact us using the contact information below:


    CRC Industries Europe BVBA
    Touwslagerstraat 1 B-9240 Zele Belgium

    32-52-45.60.11 • privacy.eu@crcind.com


  8. Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we change it, we will post the updated notice on our website and online services, and it will be effective as of the date posted. Your continued use of our website and online services following the posting of changes will constitute your acceptance of such changes.

Notice on Use of Cookies and Similar Technologies ("Cookie Notice")


BY CONTINUING TO USE OUR WEBSITE AND ONLINE SERVICES, YOU CONSENT TO THE USE OF COOKIES AND SIMILAR TECHNOLOGIES AS DESCRIBED IN THIS COOKIE NOTICE AND OUR PRIVACY NOTICE


  1. Use of Cookies and Similar Technologies

    Our website and online services use cookies and similar technologies to collect and store certain non-personal data (such as log data, location data, and cookie data) when you visit or interact with our website and online services to help us secure our website and online services, as well as the information processed by our website and online services; monitor and enhance the performance of our website and online services; better understand user behavior; and facilitate and measure the effectiveness of advertisements and website features. These cookies and similar technologies include:


  2. How Cookies and Similar Technologies are Used

    Cookies and similar technologies used on our website and online services (including the information obtained through such use) fall into four categories:


    Essential

    Our website and online services utilize first- and third-party cookies and similar

    technologies that are necessary to operate our business and maintain our website and online services, including verifying and authenticating website users; preventing fraud and securing our website and online services and databases; payment processing; enabling users to move around our website and online services and use their features; and complying with applicable laws and industry standards. These cookies and similar technologies do not gather information about you that could be used for marketing or tracking your browsing activity. This category of cookies generally cannot be disabled.

    Performance

    Our website and online services may utilize first- and third-party cookies and similar technologies to provide enhanced features and remember user preferences, including identifying return users when visiting our website (e.g., to remember your login credentials); keeping track of user preferences, interests, and past items viewed or utilized (e.g., preferred language or past purchases); and providing social features that allow users to interact with social media services through our website and online services (e.g., Facebook or Twitter, as further described below).

    Analytics

    Our website and online services may utilize first- and third-party cookies and similar technologies for analytics, product development, and market research purposes, including analyzing how users arrive at and engage with our website and online services; tracking and measuring the performance and effectiveness of our website and online services; optimizing the location of ads, website features, and other content on our website and online services; statistical reporting in connection with website activity; analyzing user preferences and behaviors and market characteristics and trends in order to develop and improve our products and services, websites, and ads; segmenting audiences to test features of our website and online services; and conducting research about our consumers, products, and online services.

    Advertising

    Our website and online services may utilize first- and third-party cookies and similar technologies to deliver, track, and measure ads both on and off our website and online services, including ads relevant to your interests (e.g., ads based on your past interaction with our website or based on predictions about your interests derived from your browsing activities on different websites over time); and ads based on your location, demographics, or device characteristics. Cookies are also used for tracking and measuring the reach and frequency of ads and regulating the delivery

    of such ads (e.g., capping the number of times you see a particular ad).


  3. Use of Cookies and Similar Technologies by Our Online Partners

    We may use vendors and other online partners to perform some of the Essential, Performance, Analytics, and Advertising activities described above, including to provide audience measurement and analytics services, to serve ads on our behalf on our website and online services and on third-party sites, and to track and report on the performance of such ads. These online partners may use third-party cookies and similar technologies to collect and store certain log data, location data, cookie data and other information when you visit or interact with our website and online services and other unaffiliated

    sites in order to identify your browser or device and provide their respective services. Further, these online partners may combine data collected on our website and online services with information collected on unaffiliated sites or with any other data maintained by these online partners. Their use of data collected on our website and online services and third- party sites will be subject to their own terms of use and privacy policies.


    For example, we may use third-party cookies to deliver our ads on third-party websites through a common form of online advertising known as "retargeting." Retargeting works by serving ads on one website based on an individual's activities on a different website (e.g., if you view a product or service on our website, you may later see ads for our products and services when you visit a third-party website). To do this, we allow our online partners (such as Google or other ad network vendors) to serve their own third-party cookies when users visit our website and online services, allowing these online partners to recognize users who have previously visited our website and online services. When these users visit a third- party website that includes features provided by our online partners (e.g., where our online partners have purchased ad space), our online partners can recognize the users' interest in our products and services and deliver one of our ads on the third-party website.


  4. Your Cookie Choices

    Most browsers are set to accept cookies by default. However, browsers typically allow individuals to remove or block browser cookies if they choose. For more information on blocking and removing browser cookies, please review your browser's Settings or Preferences tab. More information can be found here:


    Google Chrome

    Internet Explorer

    Mozilla Firefox

    Safari (Desktop)

    Opera

    Opera Mobile

    Android Browser

    Safari (Mobile)


    For other browsers, please consult the documentation that your browser manufacturer provides.


    In addition to removing and blocking browser cookies generally, the following opt-out mechanisms may be available if our website and online services utilize the third-party cookies listed below:



    The list above identifies some of the third-party cookies we may use on our website and online services. However, we may use other third-party cookies and similar technologies on our website and online services that are not listed here. This list is subject to change at any time and without notice.


  5. Social Plugins

    Our website and online services may use social plugins (e.g., the Facebook "Like" button or "Share to Twitter" button) to enable you to easily share information with others. When you visit our website and online services, the operator of the social plugin may be able to place a cookie on your browser or device, enabling that operator to recognize users who have previously visited our Service. If you have previously logged into the associated social media website (e.g., Facebook or Twitter) before visiting our website and online services, the social plugin allows that social media website to receive information about your visit to particular pages on our website and online services. The social plugin may collect this information for any such users who have logged into social networks, whether or not they specifically interact with the plugin on our website and online services (e.g., by clicking "Like" or "Share"). The social plugin may also allow the social media website to share information about your activities on our website and online services with other users of their social media website. For further details about the information shared via a particular social media plugin, you should refer to that social media site's privacy policies and terms of use.


  6. Do Not Track (DNT)

There are different ways you can prevent tracking of your online activity. One of them is setting a preference in your browser that alerts websites you visit that you do not want them to collect certain information about you. This is referred to as a Do-Not-Track ("DNT") signal. Please note that currently our website and online services do not respond to these signals from web browsers. At this time, there is no universally accepted standard for what a company should do when a DNT signal is detected.