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Business Partners Privacy Notice

<p>Solenis company and its wholly and majority-owned entities (&ldquo;<strong>Solenis&rdquo;, &ldquo;Solenis Group</strong>&rdquo;, "<strong>Company</strong>", "<strong>we</strong>" or "<strong>us</strong>") 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. Please click below to get more details about Solenis entities acting as data controllers and responsible for the processing of your personal data (<a href="/globalassets/resources/privacy-documents/list-of-solenis-group-companies-v02.pdf">List of Solenis Group Companies</a>). You can find out more about Solenis Group at solenis.com or by contacting us using the information in the Contact Us section of our website.</p> <p>This Privacy Notice has been issued for compliance with laws regulating processing of personal data, which are applicable to Solenis. Our group-wide global data privacy approach is based on the European Union General Data Protection Regulation (<strong>EU GDPR</strong>), but we also take steps to meet local data privacy laws where these impose additional or stricter requirements than our global standards. Depending on the territory where the processing operation takes place, or the territory where the data subjects are located, these local laws include (without limitations) Brazil&rsquo;s General Data Protection Law (<strong>LGPD</strong>), California&rsquo;s Consumer Privacy Act (<strong>CCPA</strong>), South Africa&rsquo;s Protection of Personal Information Act (<strong>POPIA</strong>), China&rsquo;s Personal Information Protection Law (<strong>PIPL</strong>) and all other equivalent regulations (which along with EU GDPR are collectively referred to as &ldquo;<strong>Data Protection Laws</strong>&rdquo;). To the extent permitted by applicable Data Protection Laws, this notice applies in all countries throughout Solenis global operation. As Solenis is an international company operating from multiple jurisdictions, various country-specific requirements may apply. You can review <a href="/en/country-specific-information/">Country-Specific Information</a> as part of this Privacy Notice.</p> <p>This Privacy Notice 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 Notice, and in a course of collection related to sales, marketing, business partner&rsquo;s, contractors&rsquo;, vendors&rsquo; and suppliers&rsquo; engagement (collectively "<strong>Instruments</strong>&rdquo;).</p> <p>This Privacy Notice does not apply to personal information obtained during the recruitment processes and employment relation. This will be subject to the <a href="/en/candidate-privacy-notice/">Candidate Privacy Notice</a> and Fair Processing Notice made available when your personal information is collected by the Company, for example where you send your resume or conclude an employment contract.</p> <p>This Privacy Notice 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.</p> <p>You might find external links to third party websites on our website. This Privacy Notice 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.</p> <p>Click on one of the links below to jump to the listed section:</p>
<p>Personal information is any information capable of identifying a natural person (and legal person pursuant to some jurisdictions), directly or indirectly, in particular by reference to an identification number or to one or more factors specific to the person&rsquo;s 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.</p> <p>Personal information we collect through the Instruments includes:</p> <ul> <li>contact information such as name, surname, phone and fax number, email and postal address, job title (position), company you work for,</li> <li>information used to create your online account such as username, password and security question and answer,</li> <li>customer service and purchase orders&rsquo; history,</li> <li>passport or national ID, VISA (i.e., number, expiry date, photo),</li> <li>financial information such as payment, billing address, bank account, credit score, payment card details (i.e., card number, expiration date and security code),</li> <li>location data such as data derived from your IP address, country and zip code, precise geolocation of your mobile device (where notice and choice was provided, as appropriate), clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the online Instruments and third-party websites, that we obtain through the use of cookies; and other personal information contained in content you submit to us such as through our forms: Contact Us, Ask an Expert, Product Sample Requests, Product Campaigns and webinar registration forms, MySolenis.com, eShop and HighRadius.</li> </ul> <p>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.</p> <p><strong>How we may use your personal information:<br /></strong>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.</p> <p>Depending on our relationship with you and subject to Data Protection Laws or other applicable regulations, we may use the obtained personal information to undertake the following processing activities:</p> <ul> <li>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&rsquo; samples, providing expert advice, answering your enquiries),</li> <li>manage customer relationships (i.e., including evaluating and responding to your requests, inquiries and applications, creating and administering your account),</li> <li>operate our business and comply with our contractual obligations (i.e., including performing purchases and payments, auditing, billing, reconciliation and collection activities),</li> <li>facilitate marketing communication (i.e., communicate about our products, services, events, programs and promotions by sending alerts, promotional materials, and other marketing communications),</li> <li>obtain your feedback (i.e., conduct and facilitate surveys aiming at evaluation and improvement of our business),</li> <li>comply with applicable legal requirements and regulations (i.e., verify your identity to prevent fraud and other unlawful activity, unauthorized transactions, conduct investigations).</li> </ul> <p>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 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.</p> <p><strong>Legal basis for using your personal information<br /></strong>We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this.</p> <p>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 or participating in our products, services, 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.</p> <p>In some cases, your consent may be &ldquo;implied&rdquo; (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 Data Protection Laws or other applicable regulations require your &ldquo;explicit&rdquo; consent for the collection, use and disclosure of personal information as set out in this Privacy Notice, you will be asked to provide a prior and explicit consent.</p> <p>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 the terms and conditions of a specific product, service, event, program or promotion you signed up for, participated in or purchased.</p> <p>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 with us.</p> <p>Where a legal basis other than consent is available pursuant to the Data Protection Laws or other applicable regulations in the jurisdiction in which you reside, the following table sets out our legal basis for processing your personal information:</p> <table class="privacy three-column" border="1"> <tbody> <tr> <td> <p><strong>What We Use Your Information For</strong></p> </td> <td> <p><strong>Legal Basis For Using Personal Data </strong></p> </td> <td> <p><strong>Legitimate Interests Legal Basis </strong></p> </td> </tr> <tr> <td> <p>To provide customer services support</p> </td> <td> <ul> <li>Performance of a contract</li> <li>Legitimate interests</li> </ul> </td> <td> <p>The management of our business</p> </td> </tr> <tr> <td> <p>To manage customer relationships</p> </td> <td> <ul> <li>Performance of a contract</li> <li>Legitimate interests</li> </ul> </td> <td> <p>The management of our business</p> </td> </tr> <tr> <td> <p>To operate our business and comply with our contractual obligations</p> </td> <td> <ul> <li>Performance of a contract</li> <li>Legitimate interests</li> </ul> </td> <td> <p>The management of our business</p> </td> </tr> <tr> <td> <p>To facilitate marketing communication</p> </td> <td> <ul> <li>Legitimate interests</li> <li>Consent (whenever required by</li> <li>Data Protection Laws or other applicable regulations)</li> </ul> </td> <td> <p>The management of our business</p> </td> </tr> <tr> <td> <p>To obtain your feedback</p> </td> <td> <p>Legitimate interests</p> </td> <td> <p>The management of our business</p> </td> </tr> <tr> <td> <p>To comply with applicable legal requirements and regulations</p> </td> <td> <p>Compliance with legal and regulatory obligations</p> </td> <td> <p>Not applicable</p> </td> </tr> <tr> <td> <p>To manage our website and improve your user experience</p> </td> <td> <p>Legitimate interests</p> </td> <td> <ul> <li>To ensure the effective operation of our Site.</li> <li>To ensure that content from our Site is presented in the most effective manner for you and for your computer.</li> <li>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.</li> </ul> </td> </tr> </tbody> </table> <p>&nbsp;</p> <p>In all such cases, we will look after your information at all times 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.</p> <p>If you choose not to provide us with certain personal information, to object to processing, or to withdraw your consent, where such 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.</p> <p>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).</p>
<p>To the extent permitted by the Data Protection Laws or other applicable regulations, 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 or comply with Data Protection Laws or other applicable regulations. 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 and marketing team. We do not sell your personal information.</p> <p>To the extent permitted by the Data Protection Laws or other applicable regulations, we may also share your personal information with third parties who help manage our business and services&rsquo; delivery, our technology systems and applications, internal procedures, infrastructure, advertising and marketing. 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 Instruments; (ii) government organizations and agencies, law enforcement, regulators, auditors, global trade compliance and legal advisors to comply with all applicable laws, regulations and rules; and (iii) credit checks and debts&rsquo; recovery agencies who help us to operate our business and comply with our contractual obligations to the extent it is expressly permitted by the Data Protection Laws or other applicable regulations.</p> <p>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.</p> <p>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.</p> <p>Data Protection Laws or other applicable regulations may permit or require the sharing of personal information some circumstances not described above. These circumstances include situations when permitted or required by Data Protection Laws or other applicable regulations 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 fulfill that particular purpose.</p> <p>If you reside in a jurisdiction where Data Protection Laws or other applicable regulations require your explicit consent for sharing of personal data outside the initial and specific purposes, you will be asked to provide a prior and explicit consent.</p>
<p>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 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 to ensure that transfers of personal information are in accordance with Data Protection Laws or other applicable regulations and carefully managed to protect your privacy rights and interests. Please note, however, that where your information is transferred outside of your country of residence, it will be subject to the Data Protection Laws or other applicable regulations of the jurisdiction to which it is transferred, and may therefore be accessible to law enforcement and governmental authorities in that jurisdiction.</p> <p>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.</p> <p>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 equivalent transfer mechanisms).</p> <p>You have a right to obtain more information about 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.</p>
<p><strong>Security<br /></strong>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, please contact us by using the CONTACT US section below.</p> <p><strong>Storing your personal information<br /></strong>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 Data Protection Laws or other applicable regulations.</p> <p>To the extent permitted by Data Protection Laws or other applicable regulations, 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.</p>
<p>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 <a href="/en/website-and-cookie-privacy-notice/">Website and Cookie Privacy Notice</a>.</p>
<p>Subject to certain exemptions as prescribed by the Data Protection Laws or other applicable regulations, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information, under the Data Privacy Laws applicable in the jurisdiction where you reside. Please note that your rights may be restricted in accordance with the Data Privacy Laws or applicable regulations. Click on the links below to learn more about each right you may have:</p> <ul> <li><strong>Right to access personal information<br /></strong>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&rsquo;s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.</li> <li><strong>Right to rectify or erase personal information<br /></strong>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.</li> <li><strong>Right to restrict the processing of your personal information<br /></strong>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.</li> <li><strong>Right to transfer your personal information<br /></strong>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.</li> <li><strong>Right to object to the processing of your personal information<br /></strong>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.</li> <li><strong>Right to object to how we use your personal information for direct marketing purposes<br /></strong>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.</li> <li><strong>Right to lodge a complaint with your local supervisory authority<br /></strong>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.</li> <li><strong>Right to withdraw your consent<br /></strong>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 <a href="/en/statement-data-request-form/">Data Request Form</a>, or use <a href="/en/contact/contact-us/">Contact Us</a>, or send an email to <a href="mailto:privacy@solenis.com">privacy@solenis.com</a>. 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 data securely.</li> </ul> <p>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 Data Protection Laws or other applicable regulations, for instance if your request is manifestly unfounded or excessive.</p> <p>You can exercise your rights by using the CONTACT US section below. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request.</p> <p>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.</p>
<p>This website is not designed for, or directed to, individuals under the age of 18 and will not knowingly collect personally identifiable information from individuals in this age group without prior verifiable consent of his or her 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 personally identifiable 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&rsquo;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 available steps to de-identify the information.</p>
<p>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 this web page. Please regularly check these pages for the latest version of this 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 Data Protection Laws or other applicable regulations.</p> <p>By continuing to interact with us or our services, or participate in our programs, events or promotions after the modified version of the Privacy Notice has been posted or you have been informed of such update, you are accepting the changes to the Privacy Notice. If you do not agree to the changes in our Privacy Notice, it is your responsibility to stop interacting with us and our services, and/or participating in our programs, events or promotions.</p> <p>If you reside in a jurisdiction where Data Protection Laws or other applicable regulations require your explicit consent for changes or updates to this Privacy Notice or for other changes in approach to data protection, you will be asked to provide a consent before material changes to this Privacy Notice or other changes in approach to data protection are implemented.</p>
<p><strong>CONTACT US<br /></strong>We have appointed Office of Data Privacy (ODP) to oversee compliance with this Privacy Notice. If you have any questions, concerns or complaints regarding our compliance with this Privacy Notice, the information we hold about you or if you wish to exercise your rights, we encourage you to contact our ODP by sending an email to <a href="mailto:privacy@solenis.com">privacy@solenis.com</a>, or by completing and submitting our <a href="/en/statement-data-request-form/">Data Request Form</a>, or by using <a href="/en/contact/contact-us/">Contact Us</a>.</p> <p>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 applicable Data Protection Laws.</p> <table class="privacy three-column" border="1"> <tbody> <tr> <td> <p><strong>Solenis LLC</strong></p> </td> <td> <p><strong>Solenis Switzerland GmbH</strong></p> </td> <td> <p><strong>Solenis Netherlands BV</strong></p> </td> </tr> <tr> <td> <p>Office of Data Privacy<br />Information Security Director<br />2475 Pinnacle Drive<br />Wilmington, DE 19803<br />United States<br /><a href="mailto://privacy@solenis.com">privacy@solenis.com</a></p> </td> <td> <p>Office of Data Privacy<br />Global Data Privacy Lead<br />M&uuml;hlentalstrasse 38<br />8200 Schaffhausen<br />Switzerland<br /><a href="mailto://privacy@solenis.com">privacy@solenis.com</a></p> </td> <td> <p>Office of Data Privacy<br />Regional Legal Counsel<br />The Mark Offices<br />Fascinatio Boulevard 200<br />3065 WB Rotterdam<br />The Netherlands<br /><a href="mailto://privacy@solenis.com">privacy@solenis.com</a></p> </td> </tr> </tbody> </table> <p>&nbsp;</p> <p>Last Modified: April 11, 2022</p>