Privacy Policy

This privacy policy describes how and its affiliates ("" or "we") process the personal information of our website visitors and customers. It also describes the cookies we may use and send to your computer or mobile device. Please note that this privacy policy is not an exclusive description of how processes the personal information of individuals.

If you use products or services, further information will be provided as part of the engagement process.

If you are an employee or worker of , the information about how we handle your personal information as an employee is located on the intranet and will have been notified to you. You can request a copy of the information from your HR representative.

If you are prospective employee or job applicant of , we will provide you separately with information about how we handle your personal information for recruitment purposes.

Types of Data We Collect

Personal information means information that allows someone to identify you (either directly or indirectly) or contact you. The table below sets out the types of personal information that we may collect from you and how we collect it.

We collect personal information directly from the individual to whom it relates, except where that individual has consented to collecting the personal information from a third party or the law otherwise permits to do so.

In addition to the information that we collect from you directly, we may also receive additional relevant information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

We will take reasonable steps to ensure the personal information that we store is accurate, complete and up-to-date.

Use and Processing of Your Personal Information

We will only use your personal data when the law allows us to. In addition to the uses described above, most commonly, we will use your personal information, and may share your personal data with other parties acting on our behalf, for one or more of the following purposes:

• To identify you when you visit our websites.
• To provide the products, information, and services you request or that we think you may be interested in.
• If you are a customer, to carry out our contract with you.
• To improve and personalize your experience with us.
• For order processing and to streamline your checkout and service process.
• To conduct analytics and solve problems.
• For internal administrative purposes, as well as to manage our relationship with you.
• To assess and respond to a complaint you might make to us or feedback you might give us.
• For market research purposes.
• To conduct investigations of suspicious or harmful activity.

Information for Marketing Purposes

Where you have consented to us using your personal information for marketing purposes, we may use your information to conduct marketing and data analysis or to send you updates and news concerning and its business partners.

If at any time after you have consented to us using your information for marketing purposes and you wish us to stop using your information for these purposes, please contact us.

Sharing of Personal Information

In addition to the specific situations discussed elsewhere in this policy, we disclose personal information in situations set out below. This will only take place in accordance with applicable law.

• Affiliates and Acquisitions- We may share your personal information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires our company, business, or our assets, we will also share your personal information with that company.
• Other Disclosures with Your Consent- We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
• Other Disclosures without Your Consent- We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal or regulatory process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, for audit purposes, or a violation of our policies.
• Service Providers- We may share your personal information with service providers. Among other things service providers may help us to administer our website, conduct surveys, mail communications, or provide technical support, data center services or legal advice. These service providers may collect, store, analyze, or otherwise process information on our behalf.
• Sale of Personal Information- Other than set out above, we will not sell your personal information to others.

Your Choices

You can make the following choices regarding your personal information:

• Changes to Your Personal Information- You may request that we rectify any inaccurate and/or incomplete personal information. If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy. Some of our websites allow you to modify or delete your account profile. Some personal information can also be changed by contacting us using the information in the "Contact Information" section below.
• Deletion of Your Personal Information- Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information. All requests must be directed to the contact in the "Contact Information" section below. We may also decide to delete your data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties. When we delete personal information, it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it. In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
• Revocation of Consent- If you revoke your consent for the processing of personal information then we may no longer be able to provide you certain services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, if we are unable to adequately verify your identity, or if our processing is not based on your consent. Revocation of your consent will not affect the lawfulness of processing based on your previous consent.
• Access to Your Personal information- To the extent required by law, upon request, we will grant access to personal information that we hold about you. All requests must be directed to the contact in the "Contact Information" section.
• Online Tracking- We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
• Decline to Provide- You may choose not to provide some types of personal information to us. This choice may result in our websites or their functionality not working.
• Object to Processing- You may, as permitted by law, request that we stop processing your personal information.
• Complaints- Complaints can be sent to us using the "Contact Information" details below. Some jurisdictions may also allow you to complain to a data protection authority as well.

How We Protect Personal Information

is committed to:

• seeking to safeguard all personal information that you provide to us;
• seeking to ensure that it remains confidential and secure; and
• taking reasonable steps to ensure that personal privacy is respected.

All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorized access or disclosure and loss or corruption by computer viruses and other sources of harm. We restrict access to personal information to those staff members, joint venture partners, subsidiary companies and third parties who need to know that information for the purposes set out in this privacy policy.

However, no method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Our website permits you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

Retention of Personal Information

Your personal information will be retained for as long as it is necessary to carry out the purposes set out in this privacy policy (unless longer retention is required by the applicable law). However, we will not retain any of your personal information beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymized form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

EU Considerations

To process your data lawfully in the EU we need to rely on one or more valid legal grounds. The grounds we may rely upon include:

• your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes;
• our legitimate interests as a business (except where your interests or fundamental rights override these). For example, it is within our legitimate interests to use your data to prevent or detect fraud or abuses of our website;
• our compliance with a legal obligation to which is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
• if you are a customer, because processing your personal data is necessary for the performance of a contract.

Cookies and Other Web Devices

Our website can send cookies to your web browser if your browser’s preferences allow it. Cookie settings can be controlled in your internet browser to automatically reject some forms of cookies. If you view our website without changing your cookie settings, you are indicating you consent to receive all cookies from the website. If you do not allow cookies, some features and functionality of our website may not operate as expected. We currently do not use cookies for advertising purposes.

We may use Adobe Flash technology (including Flash Local Stored Objects "Flash LSOs") that allow us to, among other things, serve you with more tailored information, facilitate your ongoing access to and use of the website, and collect and store information about your use of the website. Our website or emails may also use pixel tags, web beacons, clear GIFs, or other similar technologies to measure the success of marketing campaigns, and compile statistics about usage and response rates, and other purposes. Please address any additional questions or concerns about our cookie usage to the "Contact Information" contained in this policy.

Miscellaneous

The following additional information relates to our privacy practices:

• Minors- Our websites are not for individuals under age 18. Those individuals should not access the website or provide personal information to us.
• Transmission of Data to Other Countries- Your personal information is processed in the United States and may be transferred to other countries outside the EU, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your information. In particular, your personal data may be transferred throughout the group and to our outsourced service providers located in the United States or abroad. By submitting your personal information to us you agree to the transfer, storage and processing of your information in the United States and other countries inside or outside the EU. We will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organization, contractual or other lawful means. Please contact us using the information in the "Contact Information" section below for a copy of the safeguards which we have put in place to protect your personal data and privacy rights.
• Third Party Applications and Websites- We have no control over the privacy practices of websites or applications that we do not own, including websites to which our website provides hyperlinks.
• Third Party Personal Information- Where you submit information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their information, the reason you have provided it, how they can contact us, the terms of this policy and that they have consented to such collection, use and disclosure.
• Contact Information- If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.


,

Attn: Compliance

Changes to This Privacy Policy - We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information.