Effective Data: 16th December 2019
The following topics are covered below:
- Personal Data We Collect About You
- Personal Data We Collect Through Automated Means
- How We Protect Children’s Privacy
- How We Use the Personal Data We Collect About You
- Do Not Track
- When We Share Your Personal Data
- How Protect Your Personal Data
- How Long We Retain Your Personal Data
- Links to Other Websites
- Location and Transfer of Personal Data
- Additional State- and Country-Specific Notices
- Notice to Residents of California
- Rights of Individuals Located in the UK and European Union
- How You Can Contact Us
Personal Data We Collect About You
We collect data about you through a third-party service provider that collects information on our behalf when you interact with the Site, including when you log in to the Site, create an account, or join our mailing list. The personal data we collect includes the following information:
- Data that you provide:
- Email address;
- Phone number;
- Company name;
- Information that you choose to submit in connection with your comments or inquiries or when you apply for a job.
You are not required to provide personal data as a condition of using our Site.
Personal Data We Collect Through Automated Means
We automatically collect information about the devices that you use to interact with the Site, as well as information about how you interact with the Site. The information that we automatically collect includes the following:
- IP address and other device identifiers;
- Location (based on IP address);
- Web browser type and version;
- Pages you visit while on the Site;
- Time spent on those pages;
- Date, time and for how long you visited the Site;
- Contact information, including telephone number from device; and
- Documents you downloaded from the Site.
This data that we automatically collect may be associated with any personal data that you have provided to us.
How We Protect Children’s Privacy
The Site is a general audience site and is not directed at or designed to be used by children under the age of 16. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 16, we will promptly delete that information.
How We Use Personal Data We Collect About You
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.
If we intend to use personal data for a purpose other than the purpose for which we collected the data, we will provide you with information about this secondary purpose and any additional information necessary to ensure fair and transparent processing, before we engage in further processing.
- Performance of a contract - with you or to take steps taken to enter into it. We may use and process your personal information where:
- we have supplied you (or continue to supply you) with any products and services;
- where you are in discussions with us about any new product and where you have an account with us;
- respond to your inquiries on a product or service;
- We will use this information in connection with the contract for the supply of products when it is needed to carry out that contract with you or for you to enter into it, and to manage your account with us and administer our reward and loyalty schemes in accordance with our terms and conditions for those services.
- Legitimate interests or that of a third party - for the following purposes:
- for marketing activities (other than where we rely on your consent to do this);
- for analysis to inform our strategy, help us understand how our Site is used, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our Site);
- to operate, evaluate and improve our business, including by managing, enhancing, improving and analysing our products, to correspond or communicate with you;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
- to develop new products and services based on our analysis of consumer preferences;
- to perform other research, such as determining industry trends and growth opportunities based on consumer activity;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for prevention of fraud and other criminal activities;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for assessing the quality of the our service and to provide staff training within the business;
- for the management of queries, complaints, or claims; and
- to assist our sales and marketing teams to perform their functions.
- Compliance with a legal obligation - we will use your personal information to comply with our legal obligations:
- to assist any public authority or criminal investigation body;
- to identify you when you contact us; and/or
- to verify the accuracy of data we hold about you.
- to protect against and detect fraud, abuse or other unlawful activity; and
- Vital interests - where we have supplied you with any products, we may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
- Consent - we will ask for your consent to send you direct marketing communications, including:
- providing information about products and services that we offer, including sending promotional materials and other communications;
- delivering advertisements to you about products that may be of interest to you; and
- sending you information relating to investor relations that you request to receive.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You may at any time tell us not to send you marketing communications by email by clicking on the “opt out” or “unsubscribe” link within the marketing emails you receive from us or by contacting us as indicated below.
We may use third-party analytics services on our Site. The analytics providers may use technologies such as cookies, web server logs, and web beacons to help us analyze visitors’ use of our Site. The information collected through these technologies, including your IP address, may be disclosed to the analytics providers and other relevant third parties that use the information to analyze the use of the Site.
Do Not Track
Our Site does not collect personal data about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Site, and we do not alter our data collection and use practices upon receipt of such a signal.
When We Share Your Personal Data
Third parties providing services on our behalf. We may engage third parties to perform services in connection with our business operations. These services may include (a) products and/or experience customization; (b) distribution of marketing and promotional material; (c) website evaluation; (d) data collection, storage, management, analysis and, where applicable, deletion; and (e) other services designed to maximize our business potential. These third parties may have access to certain information, including personal data, to the extent necessary to perform their duties and functions.
Company security. We may disclose information about our users, including personal data, when legally required to do so, at the request of government authorities conducting an investigation or to verify or enforce compliance with the policies governing our company and applicable laws. We also may disclose such information when necessary to protect our rights, property or safety of GCP, our affiliates, business partners, customers or others, or to obtain legal advice.
Aggregate data. We may disclose aggregated, non-identifiable user statistics (such as the number of users who visited a page on the Site during a specific time period) to third parties for a variety of purposes, including describing our products to prospective partners and other third parties.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
How We Protect Your Personal Data
Unfortunately, the transmission of information via the internet is not completely secure. We will do our best to protect your personal information and GCP maintains physical, technical and administrative controls to reasonably safeguard personal data. No website, internet transmission, computer system or network is completely secure, however. Therefore, GCP cannot guarantee that unauthorized access to information, data loss, or data destruction or alteration will never occur. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Our Site may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our Site from a third-party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party website and recommend that you check the policy of that third-party website.
GCP will retain your personal data for as long as required to provide you with access to the Site and our services and for as long as necessary for the protection and pursuit of our legal rights and to fulfil obligations under laws applicable to our operations. After that time, GCP will destroy your personal data in accordance with GCP’s record retention schedule.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Links to Other Websites
Location and Transfer of Personal Data
Our Sites are available in countries worldwide, and information you provide to us may be stored on servers and with third-party service providers in the United States and other countries in which we do business and whose data protection laws may differ from the jurisdiction in which you live. When we transfer the personal data of users who are located in the EU and the U.K. to a location, including outside of the UK and/or EEA for processing, we use an approved transfer mechanism. A copy of the transfer mechanism that we use to effect such transfer is available to users by contacting privacy@GCPat.com.
Additional State- and Country- Specific Notices
The following additional notices apply to users located in the State of California, the EU and the U.K.
Notice to Residents of California
Pursuant to California Civil Code Section 1798.83(c)(2), GCP does not share your personal data with third parties for those third parties’ direct marketing use.
- Request to know the categories of personal information we collect about you, as well as the sources from which the personal information is collected; the business or commercial purpose of our collection; and the specific pieces of personal information we hold about you;
- Request access to and receive a portable copy of your personal information;
- Request certain information regarding, and/or opt-out of, our disclosure of your personal information to third parties;
- Request that we delete the personal information we hold about you in certain limited circumstances;
- Right to be free from discrimination in response to exercising these rights conferred by the CCPA.
- To exercise any of these rights, please contact us at privacy@GCPat.com.
Notice to Residents of the U.K. and European Union
Where applicable under the relevant local laws governing the jurisdiction in you live, you may have certain rights regarding the personal data that we maintain about you which, in certain circumstances, you will be able to exercise as follows:
- You may request a copy of the personal data that we maintain about you. If we maintain your information based on your consent or so that we could enter into a contract with you, you can also request that we provide you a copy of your data in a structured, commonly used, and machine-readable format.
- If your personal data is incorrect, you may request that we correct, amend, or delete personal data that is inaccurate or incomplete.
- You may request that we erase or restrict the processing of your personal data.
- You may object to the processing of your personal data in certain circumstances when we process your data for the purposes of our legitimate interests.
- You may withdraw your consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Subject to applicable local laws, we will comply with your request as soon as practicable, and where applicable within one month after receiving a valid request. If your request is particularly complicated, we may have to extend this period to 2 months.
Any request to exercise these rights will be assessed in accordance with applicable local laws and there may be circumstances where we are not legally required to comply with your request. For example, we may reject requests that we determine are unreasonably repetitive or that risk the privacy of others.
Access and correction may be done for free, unless requests are repetitive, excessive or unfounded, in which case we may charge you the administrative costs we have incurred handling the request. Some of these rights can be exercised online via your account. For example, you can review, modify, and delete certain information relating to your use of our Site and unsubscribe to email messages. If you are unable to manage your request via your online account, then please contact us at privacy@GCPat.com.
If you are unhappy or have concerns about the way in which we have handled your personal data, please contact us (see “How You Can Contact Us”) so that we can try to resolve the issue. We encourage you to get in touch with us first; however, you also have the right to lodge a complaint with the applicable supervisory authority.
How You Can Contact Us
GCP Applied Technologies Inc.
62 Whittemore Avenue
Cambridge, MA 02140